IP Law Daily, TRADE SECRETS—Fed. Cir.: Goodyear did not misappropriate Coda’s trade secrets or improperly omit inventorship of the asserted patent, (Dec 9, 2025)

By Saurabh Kashyap, B.A., M.A., LL.B., LL.M.

District court correctly found that Coda’s asserted trade secrets lacked specificity, secrecy, or evidence of use, and that inventorship correction failed for lack of conception proof.

The U.S. Court of Appeals for the Federal Circuit upheld a judgment as a matter of law entered by the federal court in Ohio in favor of Goodyear Tire & Rubber Company and its engineer Robert Benedict, dismissing multiple claims brought by Coda Development s.r.o., Coda Innovations s.r.o., and inventor Frantisek Hrabal. The Federal Circuit held that none of Coda’s asserted trade secrets were sufficiently definite, secret, or used by Goodyear, and that Hrabal was not entitled to be added as an inventor on Goodyear’s self-inflating tire patent (Coda Development s.r.o. v. Goodyear Tire & Rubber Co., No. 23-1880 (Fed. Cir. Dec. 8, 2025)).

Background. The plaintiff/appellant, Coda Development s.r.o., is a Czech company founded by Frantisek Hrabal. It is engaged in research and development of advanced tire technologies, including self-inflating tire (SIT) systems. The defendant/appellee, The Goodyear Tire & Rubber Company, is a multinational manufacturer of tires and rubber products. Robert Benedict, co-defendant and named inventor on the relevant patent, is an engineer employed by Goodyear. The parties briefly collaborated in 2008–2009, during which Coda presented its SIT technology to Goodyear in meetings and communications. The partnership did not progress beyond early-stage discussions and was not formalized through any licensing or joint development agreement.

Coda’s claims under the Ohio Uniform Trade Secrets Act (OUTSA) alleged that Goodyear misappropriated five trade secrets related to self-inflating tire (SIT) technology disclosed during their brief 2008–2009 collaboration. Among the asserted trade secrets, TS 7 involved a multi-functional air interface connecting various SIT components; TS 11 concerned pump and groove designs with specialized geometries and materials; TS 20 addressed air circulation systems with valves and reservoirs; TS 23 comprised internal test data showing high-pressure outputs from Coda’s prototypes; and TS 24 involved the optimal placement of a pump in the tire sidewall near the rim. Coda argued that these were disclosed confidentially and later used without permission in Goodyear’s development efforts.

Further, Coda also claimed co-inventorship for Hrabal in Goodyear’s U.S. Patent No. 8,042,586 (the ’586 patent), which covers a self-inflating tire system using a peristaltic pump embedded in the tire to draw in ambient air and regulate pressure. Coda claimed that key features of the ’586 patent were derived from its disclosed technology and sought to add Frantisek Hrabal as a co-inventor under 35 U.S.C. § 256.

At trial in 2022, a jury found that Goodyear had misappropriated all five trade secrets and awarded Coda $2.8 million in compensatory and $61.2 million in punitive damages. However, the district court granted Goodyear’s Rule 50(b) motion for judgment as a matter of law, concluding that the evidence did not support the verdict. It further denied Coda’s claims for correction of inventorship and injunctive relief. Coda appealed, arguing that the jury’s findings on trade secret use and value were supported by substantial evidence and that the district court erred in disregarding those findings when evaluating the inventorship issue.

Trade secrets misappropriation. The Federal Circuit affirmed the district court’s ruling that none of the five asserted trade secrets qualified for protection under OUTSA. Citing Novus Grp., LLC v. Prudential Fin., Inc., 74 F.4th 424 (6th Cir. 2023), and Caudill Seed & Warehouse Co. v. Jarrow Formulas, Inc., 53 F.4th 368 (6th Cir. 2022), the panel emphasized that a valid trade secret must be sufficiently definite, not generally known, and reasonably protected from disclosure.

TS 24. The court held that TS 24 had already been disclosed publicly in a 2007 PCT application (WO 2007/134556) and a 2008 Tire Technology article. Both documents described locating pumps in the tire sidewall near the rim—substantially the same concept that Coda sought to protect. Attempts to limit TS 24 post hoc by referencing “conventional tires” were rejected as inconsistent with the definitions submitted in discovery. Citing TLS Mgmt. & Mktg. Servs., LLC v. Rodríguez-Toledo, 966 F.3d 46 (1st Cir. 2020), the court held that publicly disclosed or vague information cannot qualify for trade secret protection.

TS 7, TS 11, TS 20. These trade secrets were deemed insufficiently definite and unsupported by evidence of use. TS 7 was a broad list of interface functions without describing the design principles. TS 11 and TS 20 similarly described generalized system concepts without technical specificity. The court held that expert testimony asserting Goodyear’s use of these concepts was conclusory and unsupported by detailed factual analysis, rendering it insufficient under Brooke Grp. Ltd. v. Brown & Williamson Tobacco Corp., 509 U.S. 209 (1993).

TS 23. The court found that only a subset of the test results in TS 23 had been communicated to Goodyear in a 2009 email. Coda failed to establish that Goodyear used the full scope of TS 23 or relied on it in its product development. Timing alone—i.e., Goodyear initiating a project shortly after receiving the email—was deemed inadequate to infer misappropriation.

Correction of inventorship. Coda’s correction of the inventorship claim depended on its trade secret arguments, particularly TS 24. The Federal Circuit noted that the jury had not been asked to compare the patent claims to the trade secrets, and the district court properly found that the scope of TS 24 did not align with the claims of the ’586 patent. The panel reaffirmed that inventorship requires proof of prior conception of each element of a claimed invention. Citing Fina Oil & Chem. Co. v. Ewen, 123 F.3d 1466 (Fed. Cir. 1997), and REG Synthetic Fuels, LLC v. Neste Oil Oyj, 841 F.3d 954 (Fed. Cir. 2016), the court held that Hrabal had not demonstrated such conception. As a result, the court found no error in the district court’s denial of correction under 35 U.S.C. § 256.

Conclusion. Thus, the Federal Circuit affirmed the district court’s ruling in full, holding that Coda failed to meet the legal standards for trade secret protection and inventorship.

The Case is No. 23-1880.

Judge: Cunningham, T.

Attorneys: Boyd Cloern (Steptoe LLP) for Coda Development S.R.O. Gregory A. Castanias (Jones Day) for Goodyear Tire & Rubber Co.

Companies: Coda Development S.R.O.; Goodyear Tire & Rubber Co.

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