In Ohio, Memorized Lists Can Be Trade Secrets

Law360, New York (February 26, 2008, 12:00 AM EST) -- Ohio has joined a host of other states which protect memorized customer lists (and other trade secrets) from being used competitively by former employees.

In Al Minor & Associates Inc. v. Martin, 2008 Ohio 292 (Ohio Feb. 6, 2008), the Ohio Supreme Court upheld an award of damages against a departed employee who solicited his former clients using information solely from his memory.

The court held that even in the absence of any employment contract or noncompete agreement, Ohio’s Uniform Trade Secrets Act (“UTSA”) O.R.C. §...
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