## Facts

- Sigma Chemical Company sold specialized research chemicals and developed extensive internal product and vendor files over decades.
- Product files included product identity, supplier sources, quality-control testing results, purchasing and pricing history, and customer complaints; vendor files included supplier identity and price/quality information for purchased products.
- Sigma invested substantial effort in identifying suppliers capable of meeting high purity requirements and kept its quality analyses and rejection reasons confidential.
- Foster Harris worked for Sigma as an experienced purchasing agent with access to Sigma’s product and vendor files and related internal sourcing and pricing information.
- Harris signed an agreement providing (1) a two-year post-employment restriction against working for a competitor and (2) a promise not to use or disclose Sigma’s trade secrets or confidential information.
- Within two years of leaving Sigma, Harris accepted employment with ICN Pharmaceuticals, a direct competitor.
- The district court enjoined Harris from working for ICN for two years and from using or disclosing Sigma’s trade secrets without a stated time limit.

## Issues

1. Whether Sigma’s product and vendor files qualified as trade secrets under Missouri law.
2. Whether the two-year noncompetition covenant was reasonable and enforceable despite lacking an express geographic limitation.
3. Whether an injunction against use or disclosure of trade secrets may be unlimited in duration or must be time-limited.
4. Whether Sigma was entitled to broader relief barring Harris from working for ICN in any capacity.

## Decision

- The court affirmed that Sigma’s product and vendor files constituted protectable trade secrets.
- The court affirmed enforcement of the two-year noncompetition restriction as applied to Harris’s employment with ICN.
- The court reversed the trade-secret injunction to the extent it was unlimited in duration and remanded for the district court to set an appropriate temporal limit.
- The court affirmed the district court’s rejection of Sigma’s request for broader employment restrictions.

## Legal Principles

- A compilation may be a trade secret when it reflects a unique combination of non-public information, developed through substantial effort, that provides a competitive advantage and is subject to reasonable secrecy measures.
- Under Missouri law, a noncompetition covenant may be enforceable if reasonably tailored to protect legitimate business interests; in a market with nationwide or worldwide competition, the absence of a geographic limit is not necessarily fatal when the restraint is otherwise narrow.
- Injunctions against use or disclosure of trade secrets must be limited to the time reasonably necessary for lawful competitors to independently develop or obtain the information through proper means.
- Trade secret law protects against unfair competitive advantage from misuse of confidential information but does not justify indefinite restraint when the information could be duplicated by legitimate effort over time.

## Conclusion

The Eighth Circuit upheld trade-secret protection for Sigma’s compiled product and vendor files and enforced a two-year restriction preventing a former purchasing agent from working for a direct competitor, but required that any injunction against trade-secret use or disclosure be limited to the period needed for independent lawful development of the information.


Sigma Chem. Co. v. Harris, 794 F.2d 371 (8th Cir. 1986)