third party, such as a competitor, there was no possibility of obtaining an injunction against that third party.[52] This new provision for third party liability in trade secret misappropriation cases was a drastic change from the prior law.[53] Deutsche Werft A.G. v. Waukesha Ch-uets-u Y-ugen Kaisha (???Deutsche Werft???) (1966),[54] the leading Japanese trade secret case prior to 1991,[55] illu