Under Texas law, the one-satisfaction rule states that a plaintiff is entitled to only one recovery for any damages suffered because of a particular injury. In TMRJ Holdings, Inc. v. Inhance Techs., LLC, No. 01-16-00849-CV, 2018 WL 326421 (Tex. App.—Houston [1st Dist.] Jan. 9, 2018, no pet. h.), a misappropriation of trade secrets case, defendant argued that plaintiff’s judgment against it for a $4 million reasonable royalty and a permanent injunction violated the one satisfaction rule because the calculation of a reasonable royalty contemplated the future of the misappropriated technology.
The First Court of Appeals disagreed. First, although the future of a technology is a factor in calculating the reasonable royalty, the defendant went out of business long before trial and therefore the reasonable royalty damages were not based on the actual future use of the trade secret. Rather, the reasonable royalty compensated “purely for the misappropriation of the technology, which has a present value based in part on potential for future use, regardless of whether that use came to fruition.”
Second, the testimony at trial established that the trade secret owner never intended for the trade secrets to be commercially available. Therefore, limiting the recovery to a reasonable royalty would not fully compensate the plaintiff for its damages because it would give the misappropriator what the market denied—a license. Given this reasoning, an award of both reasonable royalty damages and a permanent injunction did not violate the one satisfaction rule.