by Dennis Crouch
A jury awarded $64 million to a Czech inventor who claimed Goodyear stole his self-inflating tire technology. The district court threw out the verdict. The Federal Circuit has now affirmed that decision, holding that no reasonable jury could have found trade secret misappropriation on any of the five asserted trade secrets. Coda Development s.r.o. v. Goodyear Tire & Rubber Co., No. 2023-1880 (Fed. Cir. Dec. 8, 2025). The decision offers a thorough examination of what it means to define a trade secret with "sufficient particularity" under state uniform trade secret acts (UTSAs), distinguishing between those that describe functional outcomes versus those that identify actual protectable knowledge.
The case also continues an observable pattern at the Federal Circuit: juries finding for IP holders, only to have courts conclude that no reasonable jury could have reached that verdict. The following is an incomplete list of some of these anti-jury pro-JMOL cases from 2024 and 2025 that I've been tracking in the patent context:
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