In Re Lee M. Bass, Lee M. Bass, Inc., and Palladian Corporation, Relators

Summary

The Texas Supreme Court held that Bass’s 3‑D geological seismic data are trade secrets protected by Texas Rule of Evidence 507 and that the non‑participating royalty owners failed to show the necessity of the data for a fair adjudication of any claim. Accordingly, the Court granted conditional mandamus relief and vacated the trial court’s order compelling production of the data. The Court also declined to imply an implied covenant to develop the land and found no fiduciary duty owed to the royalty owners.