Opinion for the Court filed by Circuit Judge WILLIAMS.
WILLIAMS, Circuit Judge:
Zotos International, Inc. manufactures a number of hair care products, using an ingredient whose identity it contends is a trade secret — hereafter referred to as the "secret ingredient." Regulations promulgated by the Food and Drug Administration under § 5(c)(3)(B) of the Fair Packaging and Labeling Act (the "Act"), 15 U.S.C. § 1454(c)(3)(B) (1982), require that...
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