Plaintiffs Spartan Composites, LLC d/b/a FODS and Spartan Mat, LLC accused Defendant Signature Systems Group, LLC of misappropriating trade secrets after Signature allegedly obtained FODS’ trade secret on how to design, manufacture, market and distribute the FODS trackout mat.
Plaintiffs retained Dr. William S. Howard (“Dr. Howard”), a mechanical and electrical engineer and the owner and president of Stability Technology, Inc., to opine on the existence of two trade secrets: (a) the manner in which Plaintiffs’ FODS Trackout mat is constructed; and (b) the combination of the shape, size, structure, composition, and placement of certain mechanisms in Plaintiffs’ FODS Trackout mat.
Plaintiffs responded that Howard presented a sufficient analysis of available patents and of the potential public exposure of Plaintiffs’ alleged trade secrets.
Defendant filed a motion to strike and exclude Howard’s statements contained in his expert report under Federal Rule of Evidence 702.
Mechanical Engineering Expert Witness
Dr. William Stamps Howard holds multiple reputable degrees in and related to the subject of mechanical engineering, is a practicing design engineer specializing in industrial machinery, and is a seasoned mechanical and electrical engineer with decades of experience.
Discussion by the Court
I. Admissibility under Rule 702
A. Howard is qualified.
Defendant did not challenge Howard’s credentials directly but argued that the expert incorrectly applied his experience by ignoring and selectively utilizing pieces of evidence to arrive at his conclusions. The Court concluded that Howard’s background, certifications, and current practices establish that he is qualified under Rule 702 to provide opinions on trade secrets relating to mechanical engineering.
B. Howard’s specialized knowledge will help the trier of fact.
The Court found that Howard’s testimony may assist the jury by explaining why he believes Plaintiffs are in possession of multiple “trade secrets.”
This issue involves consideration of a variety of technical and legal factors extending far beyond one’s innate “common sense and knowledge,” and Howard’s opinion is admissible under Rule 702 because it attempted to bridge that gap with his unique specialization.
C. Howard’s testimony is based on sufficient facts or data.
Howard relied upon in-person analysis, interviews with designers, consideration of the mechanical engineering design of the relevant equipment, and review of patents and legal literature on trade secrets to arrive at his conclusions.
Defendant argued that Howard’s testimony is critically flawed because it failed to analyze the effect that certain patents have on the existence of Plaintiffs’ alleged trade secrets.
Plaintiffs responded that Howard reviewed a sufficient number of patents and addressed the issue of public exposure at various points in his report.
The Court found that Defendant’s challenge to the depth or scope of Howard’s consideration spoke to the weight of the testimony, not its admissibility. In this context, the Court was convinced that Howard’s testimony was admissible at trial, as it is sufficiently grounded in: (a) his consideration of the problem of public disclosure; (b) his specialized experience; and (c) his varied interactions with the “trade secrets” and their related legal documentation.
D. Howard’s testimony is the product of reliable principles and methods reliably applied to the facts of the case.
Defendant believed that Howard inadequately explained how certain patents or products have not critically jeopardized the potential “secret” status of Plaintiffs’ alleged trade secrets. Plaintiffs, on the other hand, highlighted Howard’s comprehensive analysis of a relevant patent and his repeated consideration of the issue of public disclosure.
The Court found that the existence of certain patents and alternative products have not precluded Howard’s expert opinion. Nor has the personal interpretation of a patent by Plaintiffs’ corporate representative rendered Howard’s conclusions inadmissible at trial. Rather, Howard’s methodology is reliable and suitable for the purpose it serves. Moreover, the Court found that Howard applied his methodology consistently and transparently to all the facts he examined.
II. Admissibility under Rule 403
Defendant argued that Howard’s “counterfactual opinion” should not be permitted to reach the ears of the jury.
The Court found that Howard’s testimony is the result of purposeful and
diligent action, imbuing it with probative value wherever Plaintiffs’ alleged “trade secrets” are concerned. As noted above, concerns about Howard’s due diligence or the extent of his analysis should be addressed at trial, not exclusion under Rule 403.
Held
The Court denied Defendant Signature Systems Group, LLC’s Daubert motion to exclude the expert opinions of Dr. William Howard.
Key Takeaway:
While Howard did not specifically address a wide array of patents or products that might have undermined his analysis, the Court is confident that counsel will, by skillful cross-examination, illuminate for the jury each error and omission in his analysis.
The factual bases and considerations of Howard’s opinions are issues of credibility, not admissibility, and to the extent Defendant believes Howard should have conducted a more thorough or complete analysis, those criticisms should be raised at trial.
Case Details:
| Case Caption: | Spartan Composites LLC, Et Al. V. Signature Systems Group, LLC |
| Docket Number: | 4:24cv609 |
| Court Name: | United States District Court, Texas Eastern |
| Order Date: | November 10, 2025 |
