United States v. Martin

Chemist Caryn Camp, unhappy at her employer INDEXX, began corresponding with Stephen Martin (defendant), owner of a competing company, and their exchanges evolved from personal topics into Martin requesting specific confidential INDEXX information as he considered starting a competing business; Camp complied, at one point saying she felt "like a spy." After Camp accidentally forwarded an email meant for Martin to an INDEXX manager, she cooperated with the FBI, and a jury convicted Martin of conspiracy to steal trade secrets under the Economic Espionage Act. Martin appealed, arguing he had no actual agreement with Camp, never intended to injure INDEXX, and that the information he received was not a protectable trade secret.