Information is said to have independent economic value when its secrecy "provides a business with a 'substantial business advantage.'"[1]

Overview Edit

"Merely stating that information was helpful or useful to another person in carrying out a specific activity, or that information of that type may save someone time, does not compel a fact finder to conclude that the particular information at issue was "sufficiently valuable . . . to afford an . . . economic advantage over others." (citation omitted) The fact finder is entitled to expect evidence from which it can form some solid sense of how useful the information is, e.g., how much time, money, or labor it would save, or at least that these savings would be 'more than trivial.'"[2]


  1. Morlife, Inc. v. Perry, 56 Cal. App. 4th 1514, 1522, 66 Cal.Rptr.2d 731, 45 U.S.P.Q.2d (BNA) 1741 (1997) (full-text).
  2. Yield Dynamics, Inc. v. TEA Sys. Corp., 154 Cal. App. 4th 547, 564-65, 66 Cal.Rptr.3d 1 (2007) (full-text).

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