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Taking reasonable steps to protect trade secrets includes a "no photography" policy and guards surrounding the building.

Opinion (Sutton): The defendants (collectively, “Howley”) were engineers for a company that supplied parts to Goodyear Tires. Howley’s company, Wyko, was having difficulty re-creating a machine Goodyear used in their tire manufacturing process, and feared losing a lucrative contract in China. Howley was invited to a Goodyear plant for unrelated reasons, and covertly took photographs of the machine in question. Howley then emailed these photos to Wyko, but was later exposed by Wyko’s IT Manager, whom worried that trade secret law may have been violated, and informed Goodyear. Howley was subsequently charged and convicted of violating trade secret law as well as wire transfer fraud. Howley appealed. The court found that Goodyear had taken reasonable steps to protect their trade secrets, including a "no photography" policy and guards surrounding the building. The Court also found that Howley knew or intended that their actions would harm Goodyear by helping a competitor. Lastly, the Court found that Howley obtained information not generally available to the public, and did so using methods they knew violated trade secret law. Therefore, the Court AFFIRMED the convictions.