Bluebonnet Petroleum v. Kolkhorst Petroleum

Bluebonnet challenged a summary judgment in favor of Kolkhorst and also appealed the denial of its motion for partial summary judgment. The appellate court affirmed, rejecting the notion that the mere identity of the potential accounts on which Robinson was working when he left Bluebonnet was a trade secret. The evidence did not show that this information was not known by others outside of Bluebonnet from a source other than Smith or Robinson. Further, Bluebonnet did not require Robinson to sign a non-compete agreement or a confidentiality agreement. There was simply no evidence that Bluebonnet had taken any steps to protect its potential client information. Nor was there any evidence that Bluebonnet expended a substantial amount of effort or funds in procuring the information. In short, the information at issue was not a trade secret.