Legal Memorandum: Qualifying a customer list as a trade secret

Issue: Under Illinois law, does a customer list qualify for protection as a trade secret?

Under appropriate circumstances, a customer list can qualify as a trade secret, but there is no per se rule affording it such status.  Compare Stampede Tool Warehouse, Inc. v. May, 272 Ill. App. 3d 580, 589 (1995) (describing "laborious method" by which customer list was compiled); Elmer Miller, Inc. v. Landis, 253 Ill. App. 3d 129, 134 (1993) (list of over 500 active, repeat customers for custom tailoring deemed a trade secret); with System Development Services, Inc. v. Haarmann, 389 Ill. App. 3d 561, 572 (2009) (customer list not protectable where employer failed to establish that names, addresses and contact information was not generally known by others or otherwise readily available); Liebert Corp. v. Mazur, 357 Ill. App. 3d 265, 279 (2005) (finding that although customer list would have required significant time, effort and expense to duplicate, it was not a trade secret due to lack of efforts to restrict access to the information).

Bridgeview Bank Group v. Meyer, 2016.IL.160042-U (Ill. App. Dist. 1 2016) (not precedential).

Date: March 1, 2016
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