Amoco Prod. Co. v. Laird

In Amoco Prod. Co. v. Laird, 622 N.E.2d 912, 918 (Ind. 1993) the Indiana Supreme Court held that information regarding the potential location of oil fields is entitled to trade secret protection. In that case, Amoco Production Company used microwave radar technology to obtain oil reserve data. See id. An Amoco geologist consulted as an expert in this technology sent a competitor a facsimile transmission of a page from a road atlas upon which he had drawn circles indicating the location of potential reserve sites. See id. The competitor, Laird, then used this information to obtain oil and gas exploration leases for a substantial portion of these reserve locations. Amoco filed an action against Laird, seeking, in part, a preliminary injunction prohibiting Laird from pursuing or developing oil and gas leases defined by the road atlas and from using or disclosing any other information gained from the discovery or litigation of the case. See id. The court held that the information pertaining to the location of the oil reserve sites was entitled to trade secret protection. The court further observed that "without the availability of [trade secret] protection, particularly with respect to exploration of subterranean natural resources, corporations and individuals would not risk the large sums of money for geophysical exploration, an expensive but only infrequently rewarding adventure." Id. at 921 (citing MILGRIM, ON TRADE SECRETS, . 2.09 (1993)).