COURTESY TEMPORARY SERVICE, INC., Plaintiff and Appellant, v. LEONEL CAMACHO et al., Defendants and Appellants, 222 Cal. App. 3d 1278

Summary

Plaintiff employment agency appealed from the denial of a petition for preliminary injunction to enjoin defendant former employees from using its confidential customer lists. Plaintiff filed the action alleging unfair competition and misappropriation of trade secrets in violation of the Uniform Trade Secrets Act, Cal. Civ. Code § 3426 et seq. The trial court enjoined defendants from soliciting or using plaintiff's employees. But while the court found defendants used the confidential customer lists to deceitfully steal customers of plaintiff, the court held such lists were work product and not protectable trade secrets. The appellate court reversed, holding that the trial court erred in denying injunctive relief because such "work effort," or process of acquiring and retaining clientele, constituted protectable trade secrets under the statute.