## Facts

- Coin Acceptors, Inc. (“Coinco”) manufactured and sold currency-handling machines through three channels: vending, amusement, and specialty markets.
- William LeJeune worked for Coinco from 1993 through multiple roles, ultimately as an Area Account Manager, operating largely from home on a company-issued laptop.
- Coinco did not require LeJeune to sign a noncompetition agreement or a formal confidentiality agreement.
- Before leaving Coinco to work for Mars Electronics, Inc. (“Mars”), a principal competitor, LeJeune copied numerous Coinco files from his laptop onto a CD and then returned the laptop.
- The copied materials included confidential pricing information for specialty markets and budgeting software reflecting manufacturing costs and profit margins.
- Coinco sued under the Maryland Uniform Trade Secrets Act (MUTSA) and sought a preliminary injunction to restrict LeJeune’s work for Mars in certain industries.
- The circuit court found misappropriation and issued a preliminary injunction, reasoning that Coinco’s trade secrets would be “inevitably disclosed” in LeJeune’s new position, causing irreparable harm.

## Issues

1. Whether the evidence supported a finding that LeJeune misappropriated Coinco’s trade secrets under MUTSA.
2. Whether a preliminary injunction restricting LeJeune’s employment could be granted on an “inevitable disclosure” theory in Maryland.

## Decision

- The court held that the evidence supported the circuit court’s finding that Coinco’s pricing, cost, and budgeting information qualified as trade secrets and that LeJeune misappropriated them by improperly copying and retaining them when departing.
- The court held that the circuit court applied an incorrect legal standard by basing injunctive relief on “inevitable disclosure,” a doctrine not adopted in Maryland.
- The court vacated the preliminary injunction and remanded for further proceedings under proper standards.

## Legal Principles

- Under MUTSA, a trade secret is information that has independent economic value from not being generally known or readily ascertainable and is subject to reasonable secrecy measures.
- Misappropriation includes improper acquisition or unauthorized use/disclosure by a person who knew or had reason to know the information was obtained by improper means.
- Maryland preliminary injunctions require consideration of: (1) likelihood of success on the merits, (2) balance of convenience, (3) irreparable injury, and (4) public interest; discretion must be exercised under correct legal standards.
- Maryland does not recognize “inevitable disclosure” as an independent basis to enjoin a former employee’s new employment; injunctive relief must be tied to actual or specifically threatened misappropriation, not speculation based on job similarity.
- Courts must avoid using trade-secret injunctions to impose de facto noncompetition restraints absent proof meeting applicable legal requirements.

## Conclusion

Maryland’s highest court affirmed that LeJeune’s copying and retention of confidential pricing and cost materials supported a MUTSA misappropriation finding, but it vacated the preliminary injunction because it improperly rested on “inevitable disclosure” rather than evidence of actual or specifically threatened misuse warranting equitable relief.


LeJeune v. Coin Acceptors, Inc., 381 Md. 288, 849 A.2d 451 (Md. 2004)