Many employers encourage their employees to create and use
LinkedIn and other social media accounts to raise their external
profiles and generate business. A recent federal court
case–Cellular Accessories for Less, Inc. v.
Trinitas, LLC, No. CV 12–06736 DDP
(SHx), 2014 WL 4627090 (C.D. Cal. Sept. 16,
2014)–suggests that whether or not an employee's LinkedIn
contacts constitute "public" information versus
protectable trade secrets is an open question.
The facts of the Cellular Accessories case are not
unlike those in hundreds of other trade secret disputes between
employers and their former employees. David Oakes (Oakes)
worked for Cellular Accessories for Less, Inc. (Cellular) as a
Sales Account Manager for six and one half years. At the
inception of his employment, he signed an employment agreement that
precluded him from removing any proprietary information from
Cellular, including Cellular's "customer base."
He also signed a statement of confidentiality that
