Coda Development s.r.o. v. Goodyear Tire & Rubber Co., (Fed. Cir. Dec. 8, 2025)

This decision provides a critical warning for companies engaged in joint development or licensing negotiations. The Federal Circuit affirmed a district court’s decision to overturn a $64 million jury verdict, ruling the plaintiff failed to establish the existence of its trade secrets and misappropriation by the defendant.

Coda sued Goodyear, alleging it misappropriated trade secrets relating to self-inflating tire (SIT) technology shared under a Non-Disclosure Agreement (NDA) and subsequently patented that technology. The jury found for Coda, but the district court granted Goodyear’s motion for judgment as a matter of law. The Federal Circuit affirmed, holding Coda’s alleged trade secrets were either publicly known (via Coda’s patent filings) or too vague to be enforceable. Consequently, Coda’s request to be added as an inventor on Goodyear’s patent was also denied.

Key Holdings & Legal Reasoning

The Court’s decision rested primarily on 3 fatal flaws in Coda’s case. First, Coda failed to define its trade secrets with particularity. The court held a plaintiff must identify the specific “design and development” knowledge (the how) that enables those functions. Second, the court found Coda previously disclosed the alleged trade secrets in an earlier patent application and an industry article. Third, Coda failed to provide use by Goodyear.

For Legal & IP Strategy

Companies should clearly distinguish between what is patented (public) and what is a trade secret (private know-how). Companies should define trade secrets as the specific tolerances, compositions, and manufacturing processes. When ordered to identify trade secrets in litigation, ensure the definition is specific enough to distinguish it from public knowledge but broad enough to cover the misappropriated technology. Keep technical documentation describing how to solve a problem separate from documentation that describes what the product does. Before meeting with a potential business partners, scrub trade secrets from slide decks and keep a log of the technical documents, files, and data transferred under the NDA.

For additional information, please contact   

Alastair J. Warr at [email protected],with any questions or more specific situations.