Coda Dev. S.R.O. v. Goodyear Tire & Rubber Co.

Authored by: Jeremy J. Gustrowsky

A recent decision has brought closure to a long-running legal dispute over self-inflating tire technology, with Goodyear Tire & Rubber Company prevailing against claims from Coda Development s.r.o. and its founder, Frantisek Hrabal. Coda alleged that Goodyear misappropriated several of its trade secrets related to self-inflating tire systems and sought to have Hrabal named as an inventor on Goodyear’s U.S. Patent No. 8,042,586. However, the Federal Circuit affirmed the district court’s ruling in favor of Goodyear, finding that Coda’s claims did not meet the legal requirements for trade secret protection or inventorship correction.

The dispute centered on five alleged trade secrets, including knowledge about optimal pump placement in a tire, specific design features for air transport interfaces, and test results demonstrating the effectiveness of Coda’s self-inflating tire prototypes. At trial, a jury initially sided with Coda, awarding significant damages. However, the district court later overturned this verdict, concluding that Coda’s trade secrets were either not sufficiently specific, not actually secret, or not used by Goodyear.

On appeal, the Federal Circuit agreed with the district court’s assessment. The court found that much of the information Coda claimed as secret had already been disclosed in patent applications and industry publications before any alleged misappropriation. For example, Coda’s own patent filings and articles described the placement of a pump in the tire sidewall, undermining the claim that this was confidential know-how. Where Coda tried to argue that its trade secrets were more specific than these public disclosures, the court noted that Coda had failed to clearly define those details in its official statements during the case.

The court also addressed Coda’s claim that Goodyear had used its trade secrets in developing the technology covered by U.S. Patent No. 8,042,586. The evidence, however, did not show that Goodyear had used the specific information Coda claimed as secret, nor that all the elements of Coda’s alleged trade secrets had been communicated to Goodyear. As a result, the court found no basis to overturn the district court’s judgment as a matter of law.

Finally, because Coda’s inventorship claim was tied to its trade secret allegations, the court also affirmed the denial of Hrabal’s request to be named as an inventor on Goodyear’s patent. The court emphasized that inventorship requires clear evidence that the alleged inventor contributed to every element of at least one claim in the patent, which was not shown here.