205 CORP. V. BRANDOW
517 N.W.2d 548 (1994)
NATURE OF THE CASE: Brandow (D) appealed a verdict in 205 Corp.'s (P) favor in P's suit
involving trade secrets.
FACTS: P hired D to manage a restaurant it owns and operates. P provided D with recipes
for The Tavern's pizza sauce, pizza crust, and grinder sandwiches. The secret recipes for
pizza sauce and grinders were known only to P's president, Charles Celsi, and by the former
owner of The Tavern. Several current and former employees knew the pizza crust recipe. P
eventually terminated D's employment. D subsequently provided pizza and grinder recipes to
his new employer, Mustards Restaurant. P sued Mustards and D personally for misappropriation
of trade secrets by Mustards and D under Iowa Code chapter 550 (1991). P also alleged that D
breached his duty of loyalty. They jury gave damages to P. The court enjoined Ds from the
use of the recipes in the future but denied P's motion for attorney fees. Mustards (D)
appealed contending that less than substantial evidence supported the jury's finding that
the recipes derived independent economic value and were the subject of reasonable efforts to
maintain their secrecy, both being requirements for recovery under chapter 550.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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