The Tenth Circuit reversed a district court's summary judgment for Beam Technologies in a trade secret misappropriation case involving John Snyder. Snyder had obtained a customer list while working for Guardian Life Insurance Company. He shared this list with Beam employees without taking precautions to maintain its confidentiality, failing to mark it as a trade secret or limit access. The court highlighted these oversights as significant in evaluating whether a valid trade secret existed.
By openly sharing the Guardian Broker List with multiple Beam employees without any restrictions or notice that the information was a trade secret, Snyder failed to take reasonable measures or efforts of secrecy under federal or Colorado law.
When Snyder sent these critical emails, he did so without any safeguards or effort to maintain secrecy. He did not mark any of the three new spreadsheets or the Guardian Broker List as confidential or a trade secret, did not limit Beam employees or anyone else's access to any of these documents.
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