the BancServices Group, Inc. and Glenn C. Ault, Jr. v. Strunk & Associates, L.P

CourtCourt of Appeals of Texas
DecidedOctober 20, 2005
Docket14-03-00797-CV
StatusPublished

This text of the BancServices Group, Inc. and Glenn C. Ault, Jr. v. Strunk & Associates, L.P (the BancServices Group, Inc. and Glenn C. Ault, Jr. v. Strunk & Associates, L.P) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
the BancServices Group, Inc. and Glenn C. Ault, Jr. v. Strunk & Associates, L.P, (Tex. Ct. App. 2005).

Opinion

Affirmed as Modified and Memorandum Opinion filed October 20, 2005

Affirmed as Modified and Memorandum Opinion filed October 20, 2005.

In The

Fourteenth Court of Appeals

____________

NO. 14-03-00797-CV

THE BANCSERVICES GROUP, INC. AND GLENN C. AULT, JR., Appellants

V.

STRUNK & ASSOCIATES, L.P., Appellee

On Appeal from the 333rd District Court

Harris County, Texas

Trial Court Cause No. 00-35446

M E M O R A N D U M   O P I N I O N


Appellee Strunk & Associates, L.P. sued appellants The Bancservices Group, Inc. and Glenn C. Ault, Jr. for misappropriation of trade secrets, breach of contract, tortious interference, and conspiracy alleging appellants copied and misappropriated Strunk=s trade secrets related to its overdraft privilege program for banks.  The jury found Ault and Bancservices misappropriated Strunk=s trade secrets, and Strunk was awarded  $601,000 in damages.  The trial court also awarded Strunk attorney=s fees against Ault.  Bancservices and Ault appeal from the judgment awarding Strunk actual damages and attorney=s fees and argue the following three issues on appeal:  (1) there is no evidence Strunk possessed trade secrets as defined under Texas law, and the evidence conclusively establishes the information could not be a trade secret because the information was voluntarily disclosed by Strunk and is commonly known; (2) there is no evidence Ault or Bancservices used Strunk=s alleged trade secrets in the conduct of their business; and (3) the trial court erred in awarding attorney=s fees against Ault.  We modify the judgment to delete the award of attorney=s fees and affirm the judgment as modified.

I.  Background

In the early 1990's, Sam Davis joined Strunk and Associates (AStrunk@), a bank consulting firm, and began to research a bank overdraft program.  Davis and other consultants at Strunk spent at least two years researching the best method for banks to address checking account overdrafts.  Strunk developed an overdraft privilege program it marketed to banks in which the banks could increase their profit from overdraft fees while the customers could avoid the embarrassment of a returned check.  By 1996, Strunk had sold the program to at least six banks and its business was growing.  Each bank agreed to pay Strunk twenty percent of its profit from the program for the first two years of the program.

Davis testified that in the early days of the program, some banks rejected Strunk=s proposal because the banks thought they could implement the program on their own.  Later, most of those banks returned to Strunk and were willing to pay for Strunk=s program.  Davis explained that while some of the components of the overdraft privilege program are well known in the banking industry, the compilation and application of those components is unique to the Strunk program.  The program provides banks with a competitive advantage and is not easy to compile from public sources without obtaining information through improper means. 


In August, 1997, Sam Pierce came to work for Strunk.  During his employment, the confidential nature of the overdraft privilege program was explained to Pierce.  Employees of Strunk were required to sign a confidentiality agreement, but Pierce failed to do so.  While working for Strunk, Pierce downloaded files concerning the overdraft privilege program from his computer at Strunk.  After leaving Strunk in January, 1998, Pierce entered into an agreement with Bill Brady and Glenn Ault to modify the materials he had taken from Strunk and use those materials plus the knowledge he learned while working at Strunk to market a program in competition with Strunk. Pierce, Brady, and Ault called their new company Impact Financial Services (AImpact@). 

After Pierce left Strunk, one of Strunk=s bank customers phoned to tell Strunk that Pierce presented a program to the bank very similar to the overdraft privilege program presented by Strunk.  Based on that telephone call and other information, Strunk initiated a lawsuit in federal court against Pierce.  In an agreement to settle the federal lawsuit, Strunk granted a license to Impact for approximately $600,000.  In July, 1999, Pierce conveyed his interest in Impact to Brady and Ault.  A dispute arose between Brady and Ault over ownership of Impact, so in November, 1999, Ault left Impact.  Ault and Pierce later agreed to create a new company to market and implement the overdraft privilege program.  The new company was called Bancservices Group, Inc. (ABancservices@).  The training, concepts, and materials from Bancservices were to be based on the Impact materials that Pierce admitted he substantially derived from Strunk.  Although Pierce attempted to obtain a license from Strunk, Pierce defaulted on the payment of the license, so Strunk revoked the license. 

Strunk filed suit in state court for misappropriation of trade secrets, breach of contract, tortious interference, and conspiracy.  Pierce settled with Strunk prior to trial.  The jury found Bancservices and Ault misappropriated trade secrets and that $601,000 would fairly compensate Strunk for any damage caused by that misappropriation.

II. 

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