The client list may not be a trade secret per se, but your friend still could be barred from doing business with her former employer's customers. There also may be other trade secrets at issue.
The information provided above is for general purposes only. It does not constitute legal advice or create an attorney-client relationship. Seek competent legal representation, because the facts of each case are different.
That its entirely proper. Fruit of the poison tree. The complaint needs to ask for the relief that is sought.Apparently the plaintiff does not care if other people contact the list but does not want former employees doing that. Seems logical. What seems illogical is for you to be continually asking Avvo questions apparently in an attempt to avoid hiring a lawyer.
I am not your lawyer and you are not my client. Free advice here is without recourse and any reliance thereupon is at your sole risk. This is done without compensation as a free public service. I am licensed in IL, MO, TX and I am a Reg. Pat. Atty. so advice in any other jurisdiction is strictly general advice and should be confirmed with an attorney licensed in that jurisdiction.
There is extensive litigation surrounding whether client/customer lists are a trade secret. You can find caselaw precedent on both sides of this question. Ultimately it will depend on the facts of your case as to whether a Judge will rule if this list is a trade secret or confidential information. Generally speaking if you can find these clients/customers in a publicly available source (yellow pages, google, even linkedin) you have a viable argument that it is not a trade secret.
Finally, it is routine for a complaint to list the companies/customers that it is looking to protect.
I would recommend that you get a good attorney to represent you, there are ways of successfully defending yourself against a covenant not to compete, but you need a good attorney. If you don't know one, go to and search:
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