The COVID-19 pandemic has ushered in a wave of changes to the
workplace, including the growing number of employees working on a
hybrid schedule or remotely. These changes present new challenges
for employers, including the further dispersion of their
confidential and trade secret materials onto mobile electronic
devices and the increased potential for misappropriation if the
employee leaves and joins a new employer. A recent decision from
the Second Circuit, Turret Labs USA, Inc. v. CargoSprint LLC et
al., No. 21-925 (2d Cir. Mar. 9, 2022), reinforces
well-established law, and serves as an important reminder, that
employers should take reasonable steps to protect the
confidentiality of their trade secret information. If not, courts
may decline to enforce the employer's rights to such
information in the event of misappropriation. Also, with the influx
of workers using personal devices or storing documentation in
remote or home office locations, employers should pay
