The Supreme Court of Ohio has ruled that the use of a memorized client list by a former employee can constitute a trade secret violation. Specifically, in Al Minor & Associates, Inc. v. Martin, the Ohio Supreme Court has determined that a trade secret does not necessarily lose its status or protection as a trade secret under the Uniform Trade Secrets Act simply because it has been committed to memory by a former employee. In other words, the Ohio Supreme Court has clarified that a trade secret is a trade secret ? regardless of whether it is in writing or memorized.

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