Procter & Gamble v. Stoneham

In Procter & Gamble v. Stoneham, (2000), 140 Ohio App.3d 260, 747 N.E.2d 268, the Court held that to show irreparable harm in the absence of an injunction, the moving party need not prove actual harm: the mere threat of harm is sufficient. In that case, a threat of harm existed where an employee possessed knowledge of an employer's trade secrets and began working in a position that caused him to directly compete with the former employer and the product line that the employee formerly directed. The Stoneham case represented Procter & Gamble's attempt to keep its identifiable trade secrets confidential. The Court held that actual harm need not be proved: the mere threat of actual harm was sufficient--it would have been impossible for Stoneham to "unknow" information about P&G's plans to "roll out" different types and brands of haircare products.