Policyholder information that was contained on printouts made from an insurance company electronic database by departing insurance agents was not protected under Connecticut trade secret law because the information was readily obtainable from physical policyholder files retained by the agents, a district court ruled. The U.S. Court of Appeals for the Second Circuit noted that, under Connecticut trade secret law, information claimed as a trade secret must not be "readily ascertainable by proper means" from another source, but the information on the printouts was identical to the information that was readily ascertainable from the policyholder files. Because the insurance company had failed to establish in the district court that the departing agents were not entitled to take the physical policyholder files and utilize the information contained within them, the company's trade secret claim necessarily failed with respect to the printouts as well.
Nationwide Mutual Insurance Co. v. Mortensen, 606 F.3d 22 (2d Cir. May 11, 2010).