Judge Lorna Schofield
Plaintiffs' proposed AutoMatic Buying Service (ABS) would permit renters of Enterprise vehicles to use smartphones to access a website designed to persuade them to buy the model driven. Enterprise later announced its own "OnRamp" service by which renters could click though an auto maker's website. Applying Missouri's Uniform Trade Secrets Act, district court granted Enterprise judgment dismissing plaintiffs' claims, including breach of a nondisclosure agreement, unjust enrichment, and trade secret misappropriation. The ABS was insufficiently secret to merit trade secret protection. It was a marketing plan comprising ideas in the public domain pieced together in an easily duplicated manner. Nor did OnRamp constitute misappropriation. It and ABS were different concepts created from a similar collection of publicly available ideas. Enterprise's disclosures in connection with OnRamp and in discussions with Mazda did not breach the parties' October 2010 nondisclosure agreement (NDA). Under the NDA, "Confidential Information" excluded such information. Also, as plaintiffs previously disclosed the ABS to Mazda, Enterprise's discussions with Mazda did not disclose plaintiffs' confidential information.