Case 3:07-cv-02748-MHP
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HARVEY SISKIND LLP IAN K. BOYD (State Bar No. 191434) Email: [email protected] SETH I. APPEL (State Bar No. 233421) Email: [email protected] Four Embarcadero Center, 39th Floor San Francisco, California 94111 Telephone: 415.354.0100 Facsimile: 415.391.7124 Attorneys for Plaintiff Mark Lillge d/b/a Creative Marketing Concepts
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS Plaintiff, v. ANDREW VERITY and CHRISTINA CHANG Defendants. Case No. C 07-02748 MHP PLAINTIFF'S IDENTIFICATION OF TRADE SECRETS Hon. Marilyn Hall Patel
Mark
Lillge
d/b/a
Creative
Marketing Concepts
("CMC")
alleges
trade
secret
misappropriation and related claims against Defendants Andrew Verity and Christina Chang. On May 31, 2007, the Court granted CMC's ex parte application for a temporary restraining order and instructed CMC to submit a document identifying the trade secrets at issue in this dispute. Plaintiff hereby identifies the following trade secrets with reasonable particularity, all of which derive independent economic value from not being generally known within Plaintiff's industry, and which are the subject of reasonable measures by CMC to maintain their confidentiality:
1 PLAINTIFF'S IDENTIFICATION OF TRADE SECRETS
CASE NO. C 07-02748 MHP
Case 3:07-cv-02748-MHP
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1.
The list of CMC customers that Plaintiff has developed over the past fifteen years,
through substantial time, effort, and expense. 2. 3. 4. The pricing which CMC charges each specific customer. CMC's actual and desired profit margin for each customer. CMC's strategic plans regarding which customers it wishes to target, and those that it
does not wish to target. 5. 6. The purchasing history of CMC's customers. The knowledge of when a customer will be due for renewal orders based upon those
customers' prior transactions with CMC. 7. Specific customer requirements, preferences, and limitations, including particular
buying habits, needs and dislikes. 8. Negative knowledge regarding goods that certain customers have refused to purchase
or no longer wish to purchase. 9. CMC's confidential marketing and financial plans, proposals and projections. HARVEY SISKIND LLP
Dated: June 1, 2007
By:
/s/ Ian K. Boyd
Attorneys for Plaintiff Mark Lillge d/b/a Creative Marketing Concepts
2 PLAINTIFF'S IDENTIFICATION OF TRADE SECRETS
CASE NO. C 07-02748 MHP