Barnes’s needs and negotiation positions, she did so at the expense and initiative of JSG. Under Illinois law, misappropriation can also be established by showing inevitable disclosure, i.e., that an employee’s new employment will inevitably lead her to rely on her former employer’s trade secrets. See Liebert Corp. v. Mazur, 357 Ill.App.3d 265, 293 Ill.Dec. 28, 827 N.E.2d 909, 927 (2005). Moreover, JSG made efforts to keep secret the details of its negotiations with Barnes and the identities of employees potentially to be placed at Barnes. For example, JSG included in France’s contract confidentiality clauses, discussed below, that obligated her not to disclose information like price lists and customer identities learned as a J pp.3d 948, 138 Ill.Dec. 508, 547 N.E.2d 675, 677 (1989) (<HOLDING>). Illinois courts also presume that pricing
holding customer list and pricing information of fire extinguisher business not a trade secret where service was commonly used so potential clients could be easily recognized and market was well established holding that the plaintiffs customer list was not a trade secret in part because there was no evidence that by the nature of the plaintiffs business extraordinary effort was involved in compiling the customer list holding that the plaintiff presented sufficient evidence to create a genuine issue of material fact that its customer list was a trade secret because the plaintiff presented evidence that the list took ten years and great expense to the company to develop holding that contact list based on inter alia information that was publicly available did not qualify as trade secret holding that a customer list may be protectable as a trade secret if it is secret and the court examines and determines if it is protectable based on three factors 1 what steps if any an employer has taken to maintain the confidentiality of a customer list 2 whether a departing employee acknowledges that the customer list is confidential and 3 whether the content of the list is readily ascertainable