Is a Company List of ''Well-Known'' Customers Considered a Trade Secret ?
In McCann Construction Specialties Co. v. Bosman, 44 Ill. App. 3d 1020, 1023, 358 N.E.2d 1340, 1342, 3 Ill. Dec. 655 (1977), the court held that a construction supply company's list of customers was not a trade secret where "there was no proof that the names on the list were not publicly available to anyone by the use of, or reference to, the yellow pages of the telephone directory or trade directories in the areas served by the parties."
The court noted that the company's list contained "names of well-known contractors, utility companies, and various park districts and municipal bodies." McCann Construction Specialties Co., 44 Ill. App. 3d at 1023-24, 358 N.E.2d at 1342.
In IKON Office Solutions, Inc. v. American Office Products, Inc., 178 F. Supp. 2d 1154, 1168 (D. Or. 2001), aff'd, 61 Fed. Appx. 378 (9th Cir. 2003) (unpublished memorandum), the court denied trade secret status to a copier equipment business's customer list.
Although that case did not involve Illinois law, we find the following language from that decision to be persuasive: "Eugene, Oregon, is a comparatively small market.
A person with a rudimentary knowledge of the industry, the Yellow Pages, and business data publicly available from sources such as the Chamber of Commerce can quickly identify the principal consumers of copying equipment in that region." IKON Office Solutions, Inc., 178 F. Supp. 2d at 1168.