Wild Horse Concepts, LLC v. Hasbro, Inc.

Syllabus

The plaintiffs, Wild Horse Concepts, LLC, Steven R. D'Aguanno, Alfred G. Vuono and H. Kirk Bozigian, appealed from a Superior Court entry of summary judgment in favor of the defendant, Hasbro, Inc., in this action involving alleged breach of implied contract, fraud, theft of intellectual property, unjust enrichment, deliberate bad faith, and wanton and willful conduct bordering on criminal conduct. Before the Supreme Court, the plaintiffs contended that the hearing justice erred in concluding that genuine issues of material fact did not exist and that their design concept did not meet the statutory definition of a trade secret pursuant to the Rhode Island Uniform Trade Secrets Act (RIUTSA).<br> <br>The Supreme Court concluded that the plain and ordinary reading of RIUTSA displaces the plaintiffs' common law claims of fraud, unjust enrichment, bad faith, and wanton and willful conduct bordering on criminal conduct resulting in punitive damages. The Supreme Court also held that there were no genuine issues of material fact because the plaintiffs cannot sidestep RIUTSA by claiming that the information they are seeking to protect is intellectual property and not a trade secret. Lastly, the Supreme Court concluded that there was no breach of implied contract because there was an express contract between the parties relating to the substance of the issue, and there can be no implied contract arising by implication of law governing the same subject matter as the preexisting contract. <br> <br>Accordingly, the Supreme Court affirmed the judgment of the Superior Court. <br>