Roger Burten submitted his "Triumph" electronic game to Milton Bradley for possible mass production, but it was rejected twice after review. One year later, however, Milton Bradley began marketing a new electronic board game under the name of "Dark Tower." There were structural and design similarities between "Triumph" and "Dark Tower." Mr. Burten brought suit for fraud, breach of contract, and trade secret misappropriation. Can Mr. Burten recover underany of these theories? [Burten v. Milton Bradley Co., 763 F.2d 461 (1st Cir. 1985)]