RULE: A showing of genuine novelty or invention may sustain claims for breach of contract, quasi-contract, and unfair competition.
Property Claim (Misappropriation): Idea submitters rarely succeed on a property theory. To be protected, an idea must be both 1) novel and 2) concrete. Necessary to show novelty generally.
Trade custom can create property rights in ideas. Because Nadel was a professional toy designer, custom in that industry governs property rights.
Contract Claim: Only necessary to show novelty to the buyer. Disclosure of an idea can be bargained-for consideration.
Novelty FACTORS: 1) specificity, 2) commonality, 3) uniqueness, 4) commercial availability.