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United States v. Martin
United States Court of Appeals for the First Circuit
228 F.3d 1 (1st Cir. 2000)
Caryn Camp was an unhappy chemist working for INDEXX, Inc. (INDEXX). While looking for jobs one day, Camp contacted Stephen Martin (defendant). Martin owned a company called WDV, Inc. Camp and Martin became pen pals, discussing their personal lives, families, and career aspirations. At first, the discussion was only casual. Soon Camp and Martin began discussing the details of their jobs, and Martin began to request specific confidential information about INDEXX. Martin expressed interest in forming a company that would compete with INDEXX. Camp provided this information, noting that she felt “like a spy” while doing so. The information exchange continued to escalate, with Camp’s providing confidential, competitive information and INDEXX property upon Martin’s request and encouragement. One day, Camp inadvertently sent an email intended for Martin to an INDEXX manager. Federal Bureau of Investigation agents approached Camp, and Camp agreed to cooperate with the prosecution of Martin for violation of the Economic Espionage Act of 1996 (EEA). In the prosecution, the jury found Martin guilty of conspiracy to steal trade secrets in violation of the EEA. Martin appealed, arguing that he had no agreement with Camp and did not intend to injure INDEXX, and that the information he received did not constitute a protectable trade secret.
Rule of Law
Holding and Reasoning (Torruella, C.J.)
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