IP Law Daily, TRADE SECRETS—N.D. Ill.: Summary judgment denied in printing company trade secrets dispute, (Mar 6, 2026)

By Kevin M. Finson, J.D.

Cross motions for summary judgment were denied because there were genuine questions of material fact as to the reasonableness of measures taken to protect the claimed secrets.

Neither party was entitled to summary judgment in a dispute over trade secrets that were allegedly brought by a former employee of a printing company to a competitor, the U.S. District Court in Chicago has held. A reasonable jury could find in favor of either party on the issues of reasonable measures to protect the claimed secrets or whether there was actual use made of the claimed secrets (Lake County Press, Inc. v. Meitzler, No. 1:23-cv-10066 (N.D. Ill. Mar. 2, 2026)).

Lake County Press, Inc. (LCP) was a printing company which acquired assets from another printing company, eDoc. These assets included customer lists and contacts. Thomas Meitzler, who had been a shareholder of eDoc and who signed the asset purchase agreement, became employed by LCP as a Senior Vice President of Sales. The asset purchase agreement and employment agreement contained confidentiality and non-solicitation clauses. Meitzler later left his employment with LCP and began working for a competitor, Graphic Arts Studio (GAS). Meitzler downloaded a local backup of his Outlook mailbox, including client files, customer data, and pricing information, from LCP’s server to his personal laptop before terminating his employment with LCP. He also communicated with customers of LCP about transferring their business to GAS while he was still employed by LCP. LCP brought suit against Meitzler and GAS for misappropriation of trade secrets, breach of contract, breach of fiduciary duty, and tortious interference with contract. Meitzler counterclaimed for violation of state wage law over a dispute about commissions he was owed by LCP. Both parties moved for summary judgment.

Trade secrets. The court found genuine questions of material fact existed as to whether LCP used reasonable measures to protect its claimed secrets, noting that they had required confidentiality agreements but also allowed employees, including Meitzler, to keep such documents on their personal devices without oversight. There were also questions as to whether the claimed secrets, such as price quotes, were actually kept confidential or if LCP’s customers were free to share them, and a reasonable jury could find that there was no proof that either Meitzler or GAS actually used the information belonging to LCP.

Wage claim. Meitzler sought summary judgment in favor of his wage claim, arguing that LCP’s written commission policy was in violation of the state wage statute by not paying commissions at the next pay cycle after they are “earned” but rather waiting for collection of the funds from the client. The court found that the statute’s use of “earned” in the context of when work was done did not prohibit LCP’s description of a commission as “earned” when a sale is made but not paid until the customer paid LCP the money from which the commission was to be taken.

Remaining claims. With regard to the claims for breach of contract, breach of fiduciary duty, and tortious interference, the court found that at the very least there were questions of material fact on the element of damages and therefore summary judgment was inappropriate as to each claim.

Sanctions. The court found that LCP had, albeit inadvertently, produced an erroneous spreadsheet regarding the commissions owed to Meitzler and failed to supplement its disclosures to correct the error. Meitzler and GAS were awarded their attorney’s fees relating to the correction.

The court granted the motion for sanctions and denied summary judgment in all respects.

The Case is No. 1:23-cv-10066.

Judge: Jenkins, L.

Attorneys: Janet A. Pioli (Karnes Law Chartered) for Lake County Press, Inc. Ronald B. Kowalczyk (Buckley Fine LLC) for Thomas Meitzler.

Companies: Lake County Press, Inc.

Cases: TradeSecrets IllinoisNews