The Second Circuit affirmed dismissal of a software trade-secret claim because the owner delegated access control to a licensee and never required anyone downstream to keep the secret.
An Eastern District of Virginia bench trial inventoried what reasonable measures look like in practice, then found misappropriation in only two of eighteen alleged disclosures.
The Eighth Circuit held that proprietary markings and confidentiality agreements were enough to keep aircraft-overhaul documents secret, even though much of their content was publicly available.
The Seventh Circuit reversed summary judgment to hold that whether a trade-secret owner took 'reasonable' precautions is almost always a jury question turning on the balance of costs and benefits.
