In Nowogroski Insurance v. Rucker, former employees of the Nowogroski insurance agency were sued for trade secret misappropriation. It was alleged that they misappropriated a customer list (by taking a written list of some names and memorizing others) that belonged to Nowogroski and used it when they went to work for a competitor. The Supreme Court of Washington held that O A. The actions of the employees did not constitute misappropriation because the customer list was not a trade secret. O B. The use of the written list by the employees constituted misappropriation but the use of memorized information did not. O C. The customer information did not constitute a trade secret because Nowogroski failed to take reasonable steps to maintain the secrecy of the information. O D. The actions of the employees with respect to their use of both the memorized information and the written information constituted misappropriation. O E. The former employees were free to use the information because they had not signed any non-compete or non-disclosure agreements with Nowogroski.

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