Is ''Information Available to Anyone In the Business'' a Trade Secret ?
In Office Mates 5, North Shore, Inc. v. Hazen, 234 Ill. App. 3d 557, 575, 599 N.E.2d 1072, 1084, 175 Ill. Dec. 58 (1992), a personnel placement agency maintained that it had a protectable interest in its client information, which included the following:
The client's name, address, and key contact person; the client's benefit package; the type of word-processing equipment the client used; its products and services; the number of its employees; the fee the client was willing to pay for placement; and the history of placements.
The court held that the client information was not protectable because the information was "readily available to anyone in the business capable of canvassing or finding a directory, whether it be the Yellow Pages or a specialized directory, placing a cold call to that business, and asking specific questions designed to elicit the information above." Office Mates 5, North Shore, Inc., 234 Ill. App. 3d at 575, 599 N.E.2d at 1084.