For one, Plaintiff has not alleged facts that bring the DNS internet traffic at issue within
the statutory definition of a “trade secret.” Plaintiff suggests that because DNS data could reveal
a compilation of sensitive information about him, it is a trade secret.13 (DE 237 at 31). That is
incorrect. To constitute a “trade secret,” as that term is statutorily defined, “the owner [must have]
taken reasonable measures to keep such information secret” and the information must “derive[]
independent economic value, actual or potential, from not being generally known to, and not being
readily ascertainable through proper means by, another person who can obtain economic value
from the disclosure or use of the information.” 18 U.S.C. 1839(3). Critically, Plaintiff fails to allege
that he or anyone else could or did derive economic value from information regarding the
frequency with which his computers interacted with certain other computers. See Kairam v. West
Side GI, LLC, 793 F. App’x 23, 28 (2d Cir. 2019) (affirming dismissal of DTSA claim in part for
failure to allege how the purported trade secret derives independent economic value from
nondisclosure). He alleges that such data has political value and that Clinton, as his political rival,
sought it for political purposes. (Am. Compl. ¶ 138). But this does not suffice to plausibly allege
a trade secret, which must derive economic value from nondisclsoure.