Martin worked for AMA, a firm that designs and administers retirement plans for 500 clients. The client list is confidential, but no agreement about that existed. When Martin left AMA after five years, he set up a competing firm and successfully solicited 15 AMA clients based on information of who they were from his memory. AMA sued for theft of trade secrets. The trial court awarded AMA damages for fees that it would have earned from the clients. Martin appealed. Is he liable?

[Al Minor & Assoc. v. Martin, 881 N.E.2d 850, Sup. Ct., Ohio (2008)]