Yeti by Molly Ltd. v. Deckers Outdoor Corp.

In this diversity action, plaintiffs claim that defendants misappropriated then-trade secrets in the design elements of a boot. Following a ten-day trial, a jury returned several verdicts against one of the defendants, Deckers Outdoor Corporation (“Deckers”), and awarded almost $2 million in compensatory damages. Deck-ers appeals, asserting that many of the jury’s verdicts were unsupported by the evidence and that the verdict form was flawed. Plaintiffs cross-appeal, faulting the district court’s refusal to award exemplary damages or attorney’s fees.

I.

In January 1989, Molly Strong (“Strong”) invented what she believed to be a better shoe. It was a winter boot, dubbed “Yeti,” incorporating innovations to maximize traction, warmth, and dryness. Strong filed a patent application for Yeti, and a patent issued in her name in September 1992:

In early 1993, Strong incorporated an entity called “Yeti by Molly, Ltd.” At about the same time, she sought a partner to help her mass produce her products. She met a man, a self-described “old shoe dog,” named James E. Granville (“Gran-ville”) who expressed interest in her designs. Strong had Granville sign a nondisclosure agreement before…