Helmet Integrated Systems Ltd v Tunnard & Otrs* (LJJ May, Lloyd & Moses;  EWCA Civ 1735; 15.12.06) - Reported at  FSR 437 (no. 16) and therefore only a short summary is provided.
The CoA held that a salesman who undertook preparatory activities to develop a concept which he intended to market in competition with his employer following his resignation was not under any fiduciary obligation to inform his employer of such activities. He was employed as a salesman, not a designer, and it was not in contemplation of either party that he would develop a product during the course of his employment. Although a fiduciary obligation may have arisen in relation to the deployment of information about a similar preparatory development by a competitor, no such fiduciary duties arose in relation to his own activities.