Nancy Drew worked for Sam Spade as an assistant private detective. Sam generously taught her everything he knew about good detective work. He also allowed her to handle assignments for some of his best corporate clients. Fly By Night, Inc., a local airline company loved Nancy’s work. The commercial carrier also realized that as a hungry young neophyte, she would work more cheaply than Sam.

Management therefore told her that they would lend her some seed money to start her own agency and that they would give her a three-year contract to work on retainer for the airline. Nancy submitted her resignation to Sam. A week later, he heard from Fly By Night that his services were no longer needed.

Does Sam have an action against Nancy for theft of trade secrets? How about for tortuous interference with contract?