ED NOWOGROSKI INC., INC. v. Rucker

— Ed Nowogroski Insurance sued former employees for soliciting its clients with confidential information. The trial court ruled that the employees had misappropriated Nowogroski’s trade secrets by retaining and using client lists and other documents. But it awarded no damages for one individual’s solicitation of clients with memorized information. Because there is no legal distinction between written and memorized information under the Uniform Trade Secrets Act (UTSA), we hold that the memorized information also constituted trade secrets and remand for a recalculation of damages.

Nowogroski…