Free Proposed Order - District Court of California - California

Case 3:07-cv-02748-MHP

Document 16-2

Filed 06/01/2007

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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

Document 16-2

Filed 06/01/2007

Page 2 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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