## Facts

- 205 Corporation owned and operated The Tavern Restaurant in West Des Moines, Iowa.
- The Tavern’s pizza sauce and grinder sandwich recipes were treated as secret and economically valuable; the pizza crust recipe was known by more employees.
- 205 Corporation hired Ron Brandow as The Tavern’s manager and gave him access to recipes in the course of employment.
- After 205 Corporation terminated Brandow, he began working for a competing restaurant group (Mustards) and provided The Tavern’s pizza and grinder recipes to Mustards.
- 205 Corporation sued Brandow and Mustards alleging misappropriation of trade secrets under Iowa’s Uniform Trade Secrets Act, Brandow’s breach of duties of loyalty/confidentiality, and Mustards’ inducement of those breaches.
- The jury awarded damages on (1) statutory trade secret misappropriation against all defendants and (3) inducement against Mustards; the trial court entered a permanent injunction barring use or disclosure of The Tavern’s recipes and any “substantially similar” recipes.

## Issues

1. Whether the pizza sauce, pizza crust, and grinder recipes qualified as “trade secrets” under Iowa’s Uniform Trade Secrets Act.
2. Whether the damages awarded for statutory misappropriation and for inducement of breach of duty constituted an impermissible double recovery for the same injury.
3. Whether the injunction barring use of The Tavern’s recipes and any “substantially similar” recipes was overbroad or improperly perpetual.

## Decision

- The court affirmed the finding that The Tavern’s pizza sauce and grinder recipes (and the protectable aspects of the crust recipe) were trade secrets supported by substantial evidence.
- The court held the damages awards were duplicative to the extent Mustards was required to pay both for misappropriation and for inducement based on the same misuse of the recipes.
- The court modified the judgment by eliminating the separate $50,000 inducement award against Mustards and left in place the larger $145,000 recovery under the statutory trade secret claim.
- The court affirmed injunctive relief but construed “substantially similar” narrowly to cover only the unique, secret aspects of the recipes, not ordinary ingredients or common techniques.
- The court indicated the injunction’s duration must be limited to the period necessary to eliminate the advantage gained from misappropriation and should not bar independently developed recipes.

## Legal Principles

- Information can qualify as a trade secret if it has independent economic value from not being generally known or readily ascertainable and is subject to reasonable secrecy measures.
- Disclosure or use of confidential information obtained through employment may constitute trade secret misappropriation when done without authorization and in breach of a duty.
- A plaintiff may not obtain multiple recoveries for the same injury merely because overlapping statutory and tort theories are pleaded and proved; courts must remove duplicative damages.
- Trade secret injunctions must be tailored to protect only the secret elements and should not function as a blanket restraint on lawful competition using public information or independently developed methods.

## Conclusion

The court upheld liability for misappropriation of The Tavern’s recipes but modified the judgment to prevent double recovery by striking the separate inducement damages, and it sustained injunctive relief only as narrowly applied to the secret features of the recipes and limited to the time needed to neutralize the misappropriation.


205 Corp. v. Brandow, 517 N.W.2d 548 (Iowa 1994)