HIP, Inc. v. Hormel Foods Corp., No. 16-3679 (8th Cir. 2018)
Annotate this CaseUnitherm filed suit against Hormel, alleging that Hormel wrongfully terminated a Joint Development Agreement (JDA) and breached a Mutual Confidential Disclosure Agreement (MCDA). Hormel counterclaimed and alleged that Unitherm breached the JDA and sought a declaratory judgment that Hormel owned the patented "Unitherm Process" for precooking bacon in a spiral oven. The Eighth Circuit affirmed the district court's grant of summary judgment, dismissing Unitherm's breach of contract claims and Hormel's breach of contract and declaratory judgment counterclaims. The court held that Unitherm failed to present evidence permitting a reasonable jury to find that Hormel wrongfully terminated the JDA; Hormel was under no contractual duty to disclose to Unitherm whether it intended to continue exploring a commercially viable method to produce precooked bacon using a process that included superheated steam in a spiral oven; the spiral test oven did not qualify as confidential information; Hormel did not breach the MCDA; and the district court did not err in denying Unitherm's request for discovery. Finally, no reasonable jury could find that Hormel became the rightful owner of Unitherm's patented process.
Court Description: Loken, Author, with Murphy and Colloton, Circuit Judges] Civil case - Contracts. The district court did not err in finding defendant had not breached the parties' joint development agreement by terminating the agreement after the project failed to develop a commercially viable oven; defendant did not breach the parties' mutual confidential disclosure agreement by disclosing to a third party, after it had terminated the joint development agreement, public information defendant acquired while the joint development agreement was in effect; a test oven did not qualify as confidential information covered by the nondisclosure agreement; as defendant did not breach the nondisclosure agreement, the district court did not abuse its discretion by refusing to permit plaintiff to discover information which might have been relevant to damages for breach; the district court did not err in concluding defendant had not established that it owned the cooking process and its patent. [ April 17, 2018
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