CMI Roadbuilding, Inc. v. Iowa Parts, Inc., No. 18-1075 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the district court's grant of summary judgment for Iowa Parts in a trademark secrets and intellectual property action brought by CMI. The court held that CMI could not establish its burden of proving that the discovery rule saves its statutory cause of action because it was on inquiry notice that Iowa Parts was making its component parts, possibly with its engineering documents and other trade secrets, starting in 2002 and continuing thereafter. The court also held that CMI was on notice of a possible problem as early as 2002 on the conversion claim. Finally, the district court properly granted summary judgment on the unjust enrichment claim where an equitable claim could not provide alternative relief.
Court Description: Beam, Author, with Benton and Erickson, Circuit Judges] Civil Case - trade secrets. District court did not err in granting summary judgment to Iowa Parts on statutory trade secrets claims, as the statute of limitations barred the action and CMI Roadbuilding cannot establish that the discovery rule saved the cause of action because it was on notice of Iowa Parts's activities and was on inquiry notice that a problem with possible misappropriation might exist before 2013. Similarly, the CMI was on notice of a possible problem as early as 2002 on a possible claim for conversion. The district properly granted summary judgment on the unjust enrichment claim, because the equitable claim cannot provide alternative relief when an adequate remedy at law existed, even if time-barred.
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