In litigation between an insurance company and its former agents, the company claimed that agents misappropriated trade secrets when they used print-outs from the electronic files of insurance policyholders in their search for other jobs. However, the court found that because the same information from the password-protected electronic files was readily available in another format, unsecured physical files stored in the agents’ offices, it cannot be considered a protected trade secret. ( Nationwide Mutual Insurance v. Mortensen et al, U.S. Court of Appeals for the Second Circuit, No. 08-5214-cv, 2010)Nationwide_v_Mortensen.pdf