Hallmark Cards v. Monitor Clipper Partners, No. 13-1905 (8th Cir. 2014)Annotate this Case
After the company it hired to compile research on the greeting cards market, Monitor, transmitted confidential market research it had prepared for Hallmark to a private equity firm, Clipper, Hallmark filed suit against Monitor and Clipper. Hallmark settled with Monitor and a jury awarded Hallmark compensatory and punitive damages in the case against Clipper. The court concluded that the jury had sufficient evidence to find that Hallmark's PowerPoint presentations constituted trade secrets under the Missouri Uniform Trade Secrets Act, Mo. Rev. Stat. 417.450 et seq; the jury verdict did not give Hallmark a double recovery where Hallmark's settlement with Monitor and its jury verdict against Clipper compensated Hallmark for independent injuries and no reduction of the jury award was necessary; and the punitive damages against Clipper were permissible under Missouri law where defendant acted with reckless disregard for Hallmark's rights and the Due Process Clause where it was not grossly excessive. Accordingly, the court affirmed the district court's denial of Clipper's motion for judgment as a matter of law and, alternatively, to alter or amend the judgment.
Court Description: Civil case - Misappropriation of Trade Secrets. There was sufficient evidence for the jury to conclude that a series of PowerPoint presentations were trade secrets under the Missouri Uniform Trade Secrets Act; the award against defendant did not give plaintiff a second recovery for a single injury as its settlement with another defendant on a breach of contract claim redressed an independent injury; punitive damage award affirmed as there was evidence defendant acted with reckless disregard for plaintiff's rights and the amount of the award is not grossly excessive and a violation of due process.