The US Court of Appeals for the Federal Circuit affirmed a district court’s judgment as a matter of law (JMOL) that the plaintiff failed to prove misappropriation of five alleged trade secrets related to self-inflating tire (SIT) technology and separately rejected the plaintiff’s claim for correction of inventorship of defendant’s patent related to the alleged trade secrets. Coda Dev. S.R.O., et al. v. Goodyear Tire & Rubber Co., et al., Case No. 23-1880 (Fed. Cir. Dec. 8, 2025) (Lourie, Dyk, Cunningham, JJ.)
Coda sued Goodyear in the Northern District of Ohio, alleging that Goodyear misappropriated trade secrets disclosed during SIT-technology collaboration discussions and that Coda’s founder should be added as an inventor on Goodyear’s patent related to the same technology. A jury initially found for Coda on five trade secrets (TS 7, 11, 20, 23, and 24) and awarded more than $64 million in compensatory and punitive damages. The district court, however, granted Goodyear JMOL, holding that the asserted trade secrets were insufficiently definite, not secret, and/or never used or disclosed by Goodyear. It later denied Coda’s inventorship claim of a Goodyear patent related to the alleged trade secrets after a bench proceeding. Coda appealed.
Trade secret claims
TS 24 concerned the “optimal” pump location in a tire sidewall above the rim. The Federal Circuit found that Coda had already disclosed this placement in a 2007 PCT application and a 2008 Tire Technology article, both of which discussed pump placement in the sidewall. At trial, Coda confirmed that these publications described the same location. The Federal Circuit determined that because the information was public, it could not be a trade secret.
Coda’s attempt to narrow TS 24 post hoc by adding qualifiers such as “conventional tire sidewall” failed because those limitations did not appear in Coda’s interrogatory responses in compliance with the district court’s order to provide “a complete list of the trade secrets (with particularity).” The Federal Circuit rejected Coda’s attempt to belatedly introduce additional specificity into the trade secret based on trial testimony and attorney arguments.
The Federal Circuit similarly affirmed that TS 7, 11, and 20 (which described broad categories of SIT system components and functions) failed the definiteness requirement. Each trade secret identified a list of desired features but did not specify the underlying “design and development” knowledge Coda claimed to own. Without a concrete articulation of the claimed technical know-how, the Court found that the descriptions were too vague to distinguish trade secret information from general design concepts already known in the field.
TS 23 comprised a set of pump-pressure test results. At trial, Coda offered only a single 2009 email that mentioned one of the pressure values listed in TS 23. The Federal Circuit found that this partial overlap could not sustain a verdict of “use,” particularly when no evidence showed Goodyear had received or relied on the totality of the testing data. The Court also found that Coda’s arguments about Goodyear proceeding with its SIT project after the email failed to establish a causal link to TS 23.
Inventorship challenge
Coda argued that because Goodyear allegedly misappropriated TS 24 and used it in its patent, Coda’s founder should be named as an inventor. The Federal Circuit rejected this argument, finding that the trade secret claims failed and left no basis for an inventorship claim tied to misappropriated information. Even on the merits, the district court found, and the Federal Circuit agreed, that TS 24 and the patent claims did not cover the same subject matter. Because inventorship requires proof of conception of every claim element, Coda’s alleged trade secrets could not supply the necessary evidence to sustain the claim.
Practice note: This decision underscores the heightened requirement that trade secrets be articulated with specificity, especially in technical fields. Describing categories of features or broad functional capabilities is insufficient; plaintiffs must isolate the precise technical information claimed to be secret. The decision also confirms that public disclosures, even by the plaintiff, are fatal.
