Saturday, December 9, 2006

Target v. Doe Federal Court Case

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION


Target Corporation, a Minnesota
corporation,

V

JOHN DOE, 1 :06-CV-2116
Defendant

For its Complaint, plaintiff Target Corporation ("Target") states and alleges as
follows

INTRODUCTION

Target brings this action against an Internet user who is deliberately posting Target
copyrighted, confidential, proprietary, and trade secret information across the Internet,
including to a website hosted in Minnesota. Target seeks an injunction against Defendant, as
well as other available legal and equitable relief arising from Defendant's tortuous actions .
PARTIES
1 . Target is a Minnesota corporation with its principal place of business in
Minneapolis, Minnesota .
2 . The true name and capacity of Defendant is unknown to Plaintiff at this time
Defendant is known to Plaintiff only by his Internet username "Target Sucks ." Additionally,
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 1 of 29

2
mrpauljrogers@yahao com, chams46Chotmail .com, anonymousematl2@aol com,
ILovePie@yahoo.com, and usembassysouthafi-ica@hotmail.com
JURISDICTION AND VENUE
3 This Court hasjurisdiction under 17 U .S C § 101 et seq, 28 U .S .C.
§ 1331(federal question); and 28 U .S C § 1338(a) (copyright) . This Court also has
jurisdiction over this matter under 28 U .S C. § 1332(a)(1) because the matter in controversy
exceeds the sum or value of $75,000, exclusive of interest and costs, and is between citizens
of different states .
4 . Venue in this District is proper under 28 U S C § 1391 and/or 28 U .S.C
1400(a). Although the true identity of Defendant is unknown to Plaintiff at this time, on
information and belief, Defendant resides in the State of Georgia and a substantial part of the
acts of infringement and rrusappropriahon complained of herein occurred in this District .
FACTUAL BACKGROUND
Target's Business and Valuable Intellectual Property
5 Target owns and operates retail merchandise discount stores across the United
States . Today, Target operates more than 1400 TARGET stores, including more than 45
TARGET stores in Georgia
6. As part of its effort to protect its retail stores from physical threats and
financial losses, Target, through considerable effort and expense, has created loss prevention
procedures and protocols . One of the key loss prevention protocols created by Target is
Target's Asset Protection Directives ("Target AP Directives")
7. The Target AP Directives are a set of written methods, techniques and
processes that are used by Target's asset protection personnel to secure Target's merchandise
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 2 of 29

Internet at the website wrAw .targetunion .org .
and other property from theft, and to deal with the apprehension of shoplifters and other
wrongdoers .
8 . The Target AP Directives are Target copyrighted, confidential, proprietary,
and trade secret information .
9 The Target AP Directives include information that is not generally known to
the public or in the industry .
10 . Target goes to considerable measures to protect the secrecy of this
information The Target AP Directives are password restricted and only available to those
employees with a "need-to-know," namely, the asset protection team .
11 . Target has an Information Security Policy where all employees, before
commencing their employment, sign an acknowledgement agreeing to maintain the
confidentiality of Target's non-public information . and to never disclose it to anyone outside
of the company.
Defendant's Improper Use of Target's AP Directives
12. On or around June 29, 2006, Defendant acquired a copy of Target's AP
Directives from a recently terminated Target employee, Scott Hundt ("Hundt") . Upon
information and belief, Hundt only knew Defendant because of his anti-Target website
postings Hundt sent a copy of the Target AP Directives to Defendant by email
13 Hundt, as a former asset protection specialist at a Target store in Wisconsin,
improperly kept the Target AP Directives upon termination .
14. On Sunday, July 2, 2006, Hundt also posted the Target AP Directives on the
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 3 of 29

4
15 . On or around July 10, Target learned of Hundt's improper disclosure to
Defendant and the Internet. Shortly thereafter, Target contacted Hundt by telephone Hundt
returned Target's telephone call and acknowledged his wrongdoing . Hundt immediately
deleted all references to the Target AP Directives from his hard drive and from the Internet .
16 . Target also demanded that Hundt contact Defendant and request that
Defendant destroy the Target AP Directives, delete any Internet postings of the Target AP
Directives posted by him, and never use them again . Hundt stated that he did not know
Defendant's name or address, and did not personally know him, but had his email address .
Hundt emailed Defendant and requested him to remove the postings, but Defendant failed to
respond.
17. Hundt also provided Target with the email address that Hundt had for
Defendant Target emailed Hundt a cease and desist letter at that address, but received no
response .
18 Instead of abiding by Target and Hundt's demands to remove the Target AP
Directives, Defendant began posting the Target AP Directives on various retail-employee
forums on the Internet, including the following locations :
http //targetsucks elevation24 coin
http //tivwtiv. targeiuniora org
http 11bullseyebb .aivardspace coin
http ://targetstoressuck blogspot corn
http //wwtiv retail-worker corn
http .//people tribe net
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 4 of 29

5
19. Beginning on or around July 12, 2006, Target, through its counsel, sent
demand letters to the moderators and administrators of the websites that posted Target AP
Directives. Target advised them that Defendant, under the alias "Target Sucks," was posting
improperly Target copyrighted, confidential, proprietary, and trade secret information . (A
copy of a sample letter sent to the moderators/administrators is attached as Ex . A )
20. In conjunction with writing to the moderators and/or administrators, Target
also attempted to contact Defendant directly by sending private messages to Defendant
through the forums . (A copy of two sample emails sent to Defendant are attached as Ex . B.)
21 In response to Target's demand letters, the administrators and/or moderators
removed the Target AP Directives from their websrtes .
22. Defendant, however, did not respond to Target's email messages . Instead,
Defendant re-posted the Target AP Directives as soon as the moderator and/or administrator
removed them from the website. Target re-contacted the moderators and/or adrrunistrators,
and the information was again deleted . Indeed, at least one of the websites -
http //targetstoressuck blogspot.com - terminated Defendant's blog .
23 . On July 27, 2006, the moderator of -www .retail-worker coin posted Target's
cease and desist letter on its website and explained why she deleted Defendant's posting of
the Target AP Directives . An exchange between Defendant and the moderator ensued,
whereby Defendant admitted that he was posting the Target AP Directives for no reason
other than to harm Target . (A copy of the email exchange is attached as Ex C .)
24. Since July 27, 2006, Defendant continues to re-post (or attempt to re-post) the
Target AP Directives on the Internet At websites where his blog was inactivated, he has
changed his username in order to be able to re-post the Target AP Directives
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 5 of 29

6
25 . Defendant's actions are a complete and intentional disregard of Target's
property rights . Since July 27, 2006, Defendant had posted on numerous websites that
"Target's lawyers are monitoring this website ." In response to Target's cease and desist
letter, Defendant states on the Internet that he does not care whether the Target AP Directives
are copyrighted or trade secrets :
As to whether or not said info is in some form `protected', I have no idea and
don't care I saw it both online already posted and via email and if someone at
T let the cat out of the bag then that is between T and them . I didn't sign any
confidentiality agreement with them and really don't give a rats ass if they like
it or not .
(A copy of the posting is attached hereto as Ex . D )
26. Defendant has never responded to Target's demands for Defendant to cease
and desist posting the Target AP Directives .
27 . Through various investigative techniques employed by Target over the last
few weeks, Target believes that Defendant uses America On-Line as his Internet Service
Provider Target believes that information obtained in discovery will lead to the verification
of Defendant's true name and address
C OUNT I
Infringement of Copyrights
28 Target realleges and incorporates by reference herein the foregoing allegations
of the Complaint .
29 Target is, and at all relevant times has been, the copyright owners of exclusive
rights under United States copyright law with respect to certain copyrighted Target AP
Directives .
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 6 of 29

7
30 . The Target AP Directives are subject to a valid Certificate of Copyright
Registration issued by the Registrar of Copyrights to Target as specified on Exhibit E
31 . Among the exclusive rights granted to Target under the Copyright Act are the
exclusive rights to reproduce the Target AP Directives and to distribute the Target AP
Directives
32 . Defendant, without the permission or consent of Target, has used, and
continues to use, the Internet, to disserrvnate and/or make available for distribution to others,
the Target AP Directives .
33 . Defendant's dissemination of the Target AP Directives is deliberate, willful,
malicious, oppressive, and without regard to Target's proprietary rights
34 . As a result of Defendant's infringement of Target's copyrights and exclusive
rights under copyright, Target is entitled to statutory damages pursuant to 17 U S .C § 504(c)
against Defendant for each infringement by Defendant . Target is also entitled to its
attorneys' fees and costs pursuant to 17 U S C . § 505 .
35 Defendant's copyright infringement, and the threat of continuing infringement,
has caused, and will continue to cause, Target repeated and irreparable injury . It would be
difficult to ascertain the amount of money damages that would afford Target adequate relief
at law for Defendant's acts and continuing acts, and a multiplicity ofjudicial proceedings that
would be required Target's remedy at law is not adequate to compensate them for the
injuries already inflicted and further threatened by Defendant . Therefore, Defendant should
be restrained and enjoined pursuant to the Copyright Act, 17 U S .C. § § 502 and 503
COUNT II
Misappropriation of Trade Secrets
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 7 of 29

Court
36. Target realleges and incorporates by reference herein the foregoing allegations
of the Complaint.
37 Defendant acquired confidential and proprietary information belonging to
Target.
38 Defendant was advised that the information he acquired was Target trade
secret information that should not be used or disclosed by him .
39 After receiving notice of the confidentiality of the Target trade secret
information, Defendant had a duty to Target to maintain the secrecy of this information and
limit its use for the benefit of only Target .
40. This confidential and proprietary information had independent economic value
because it was not generally known to or readily ascertainable by persons outside of Target
41 Target intended to keep this information confidential and has made reasonable
efforts under the circumstances to maintain the secrecy of the information .
42. Defendant has used and/or disclosed, and continues to use and/or disclose,
such information without the express or implied consent of Target, for the benefit of himself .
Such use constitutes a violation of Ga Stat . § 10-1-760 et seq, and Georgia common law
principles against misappropriation of trade secrets
43 . As a direct and proximate cause of Defendant's misappropriation of trade
secrets, Target has been damaged in an amount greater than $75,000, the specific amount of
which shall be determined at trial In addition, Target has suffered irreparable harm and will
continue to suffer irreparable harm unless the conduct of the Defendant is enjoined by this
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 8 of 29

9
WHEREFORE , Plaintiff Target Corporation respectfully requests judgment against
Defendant as follows :
An injunction, among other things, prohibiting Defendant from disclosing and
using the Target AP Directives and requiring Defendant to delete all Internet postings created
by him of the Target AP Directives ;
2. Statutory damages for each infringement pursuant to 17 U .S.C § 504;
Recovery of Target's costs and attorneys' fees incurred herein ; and
4 Any further relief that the Court deems just and equitable .
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 9 of 29

1 0
DUNCAN & MANGIAFICO, PC :
,., Dated. September 1, 2006
nnife C Adair (#001901)
uite 220
7000 Central Parkway
Atlanta, GA 30328
Telephone. (770)698-4560
Facsimile : (770)698-4565
FAEGRE & BENSON LLP :
s/Dara Mann
Dara Mann (#469065)
Suite 1900
3350 Riverwood Parkway
Atlanta, GA 30330
Telephone : (678) 627-8190
Facsitrule• (612) 766-1600
ATTORNEYS FOR PLAINTIFF
TARGET CORPORATION
Of Counsel
(upon admission pro hac vice)
James R. Steffen (MN #469065)
Kerry L. Bundy (MN #266917)
Faegre & Benson
2200 Wells Fargo Center
90 South Seventh Street
Minneapolis, MN 55402
Telephone : (612) 766-7000
Facsimle : (612) 766-1600
M2 2 08193 8 3 0 4
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 10 of 29

KERRY L BUNDS
kbundy"4fargrc cum
(6121766 .821
'lien" VIA E-MAIL
Administrator of "Return of the Target Sucks" Website
VIA E-NL4[L
Dear "Jen"/Ms . Destree :
EXHIBIT A
FAEGRE
BENSON _1
U \ I TFn ST47 F5 F NG LAND GERMANY C HINA
July 11, 2005
Jennifer Destree
Registrant of elevation24 .com
733 Hickory Avenue
Orangevale, CA 95662
Re. Improper Disclosure of Target's AP Directives on Website
We represent Target Corporation and Target Brands, Inc . (collectively, "Farget") in
connection with intellectual property matters and in connection with their ongoing efforts to
maintain the security and confidentiality of its proprietary information We are writing to you in
your capacity as Administrator and/or Registrant of the blog website
http //targetsucks elevation24 com to advise you that a post to the website contains Target
confidential, proprietary and trade secret information that has been improperly disclosed In
addition, the post wrongfully reproduces copyrighted material belonging to Target
[n case you were not aware, on July 2, 2006, user name "Target Sucks" posted to your
website Target's 2006 Asset Protection Directives . These directives include information which
is used in the conduct of Target's asset protection program and is not generally known to the
public or in the industry. Target goes to considerable measures to protect the secrecy of this
information As it appears from your posts that you are a current and,lor former Target
employee, you are most likely aware that under Target's policies and procedures, any Target
employee who is given access to the Asset Protection Directives is required strictly to maintain
the confidentiality of this information
As we hope you can appreciate, Target considers the improper disclosure of its 2006
Asset Protection Directives on the "targetsucks" website to be a very serious matter . Allowing
Target's confidential and proprietary security procedures to remain posted on the website
provides potential wrongdoers with a blueprint for circumventing Target's security procedures in
connection with shoplifting or other criminal activity This not only jeopardizes Target's
property, but also could jeopardize the safety of Target customers and employees
220 0 WE LLS FAR GO CE NTER 90 SOUTH SEVE NTH STREET N71 yINE 4P OL]S MINNESOTA SS4D2 39 0 1
TELEPH O NE 612 7ss - 7 0 0 o FACSIMILE 612 7 6 6-160 0 WWW FAEGRE CO M
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 11 of 29

M2 208102 34 01
Jennifer Destree
July 11, Zoos
Page 2
We note that the rules of your forum expressly state that "Me owners of Return of the
Target Sucks reserve the right to remove, edit, move or close any thread for any reason ." Under
the circumstances here, Target asks that you remove the July 2, 2006, and any other posting of
Target's 2006 Asset Protection Directives at your earliest possible convenience
In addition, to allow us to follow up directly with the individual who wrongfully posted
the 2006 Asset Protection Directives, we ask that you promptly supply us with contact
information for poster "Target Sucks "
Your anticipated cooperation is appreciated, and we look forward to receiving prompt
confirmation that you have removed the 2006 Asset Protection Directives from your site and to
your provision of contact information for the individual that posted the2006 Asset Protection
Directives.
Sincerely,
erry L Bundy
KLB/rew
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 12 of 29

EXHIBIT B
Bundy, Kerry L.
From, Bundy, Ke rry L
Sent : Monday, July 17, 2006 2 46 PM
To: 'annonymousemad2@aol com'
Subject: RE Improper Posting of Target 2006 AP Directives
Attachments : scan pdf
s can p df (78 KB)
Please review the attached letter . Thank you .
Kerry Bundy
Faegre & Benson
2200 Wells Fargo Center
90 S . 7th St .
Minneapolis, MN 55402
612-766-8217
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 13 of 29

VIA E-MAIL
Dear Sir/Madame-
TELEPHONE 672 -766-70 00 1 F A CSI MILE 612 - 7 5 F - 560 9 1 %tiWW FAEGR h l'OM1t
FAEGRE
BENSON
UNITED STATES ENGLAND GERMANY I C HIN A
July 17, 2006
Username "Targetsuc ks"
annonvmousemail2 u,ao l. corn
Re: Improper Disclosure of Target's AP Directives on Internet
K ERRY L.. BI11JD t
k burdyf.4faegrc com
(6 121 766-82 1
We represent Target Corporation and Target Brands, lnc (collect ively, "Target") in
connect ion with intellectu a l property matters and in connection wit h thei r ongoing efforts to
maintain the security and confidentiality of its proprietary information This l etter is to advise
you t hat certain postings made by you of t he Target 2006 Asset Protect i on Directives on the
websi t es http•//targetsucks.elevation24 eom, hitp://www targetunion.org,
hltp.//bullseyeb8 awardspace coin, and http //targetstoressuck blogspot.com contain Target
copyrighted, confidential, proprietary and trade secret information that has been improperly
disclosed.
As you know, the Target 2006 Asset Protection Directives include information which is
used in the conduct of Target's asset protection program and is not generally known to the
public or in the industry . These directives also include copyrighted material As we believe
you also know, Target goes to considerable measures to protect the secrecy of this
information Under Target's policies and procedures, any Target employee who is given access
to its Asset Protection Directives is required strictly to maintain the confidentiality of this
information Access to these directives are restricted to Target AP employees and under no
circumstances are they to be distributed to anyone outside of Target .
Target considers the improper disclosure of its 2006 Asset Protection Directives on the
Internet to be a very serious matter . Allowing Target's confidential and proprietary security
procedures to remain posted on the website provides potential wrongdoers with a blueprint for
circumventing Target's security procedures in connection with shoplifting or other criminal
activity. This not only jeopardizes Target's property, but also could jeopardize the safety of
Target employees and guests
It is our understanding that, although you were provided improperly with the Target 2006
Asset Protection Directives by a former Target employee, that person has requested that you
delete all postings made by you that contain the Target 2006 Asset Protection Directives We
hope and expect that upon review of the facts set forth in this letter, you will delete all such
2200 WEL LS FARGO CENTER I 9 0 SOUTH S EVFNTH S TRF FT I M17 INYCAPOLIS MINNESOTA S5a0 1-3 9 61
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 14 of 29

h12 20910 329 0 3
Targetsucks
July 17, 2006
Page 2
postings at your earliest convenience . Target also requests that you immediately destroy all
paper and electronic copies of the Target 2006 Asset Protection Directives in your possession .
Please provide us with prompt, written confirmation of your compliance with these requests no
later than noon on Tuesday, July 18, 2006 . If we do not receive timely confirmation from you,
we will assume that you do not intend to remove your wrongful posts, and we will proceed to
consider and take further appropriate action .
Your anticipated cooperation is appreciated .
Sincerely,
CJ
Kerry undy
KLB/rew
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 15 of 29

July 27, 2006
VIA E-MAIL
Dear Sir/Madame .
T F I F 11110N' F 612-7 6 5 7 000 HALS1%111 F 617 766 1600 %VW%Y F AI'C R F C UN7
COPY FAEGRE C OPY
BENSON
lLP
UNITED STATES I ENGLAND GERMANY ' CHINA
KERRY L B[,T1DY
kbundy i~ faegre coin
(6 12) X 65- 82 1 1
Username "Targetsucks"
Re: Improper Disclosure of Target's AP Directives on Internet
We represent Target Corporation and Target Brands, Inc. (collectively, "Target") in
connection with intellectual property matters and in connection with their ongoing efforts to
maintain the security and confidentiality of its proprietary information . This letter is to advise
you that certain postings made by you of the Target 2006 Asset Protection Directives on the
website http //Kww retail-worker coin contain Target copyrighted, confidential, proprietary and
trade secret information that has been improperly disclosed .
As you know, the Target 2006 Asset Protection Directives include information which is
used in the conduct of Target's asset protection program and is not generally known to the
public or in the industry These directives also include copyrighted material . As we believe
you also know, Target goes to considerable measures to protect the secrecy of this
information Under Target's policies and procedures, any Target employee who is given access
to its Asset Protection Directives is required strictly to maintain the confidentiality of this
information Access to these directives are restricted to Target AP employees and under no
circumstances are they to be distributed to anyone outside of Target
Target considers the improper disclosure of its 2006 Asset Protection Directives on the
Internet to be a very serious matter. Allowing Target's confidential and proprietary security
procedures to remain posted on the website provides potential wrongdoers with a blueprint for
circumventing Target's security procedures in connection with shoplifting or other criminal
activity This not only jeopardizes Target's property, but also could jeopardize the safety of
Target employees and guests.
We hope and expect that upon review of the facts set forth in this letter, you will delete
all such postings at your earliest convenience . Target also requests that you immediately destroy
all paper and electronic copies of the Target 2006 Asset Protection Directives in your possession .
Please provide us with prompt, written confirmation of your compliance with these requests no
later than noon on Tuesday, July 18, 2006 If we do not receive timely confirmation from you,
we will assume that you do not intend to remove your wrongful posts, and we will proceed to
consider and take further appropriate action
2 200 wbLtS FA UCO C F VT FK 90 SOUT H yF.v h `T H ST1tFF 7 t11 NtYrA P OL 1 5 M1uNVk SUTA SS ao 2-7 901
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 16 of 29

M2 20814344 01
Targetsucks
July 27, 2006
Page 2
Your anticipated cooperation is appreciated.
Sincerely,
Kerry L. Bundy
KLBlrew
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 17 of 29

WORKER
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Guess I'll hang out here then .
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sleK Says:
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Most Recently
Commented
Home » Forum * Specific Stores * Target Employee Forums Anyone Know Why
The Target Sucks Forum Is Down?
Anyone know why the target sucks forum is- down?
Submitted by backroompeon on Mon, 02/13/2006 - 1 14am.
I am sorry to see it gone . And I had been on there earlier tonight .
loin or register to post comments j f I11 I ~ I 0 I aY ILo Ile I
P5
Targetflowslave
Says:
Mon, 02/13/2006 -
5 2 4am
redandkhak i
Says:
Thu, 02/ 1 6/2006 -
11 23am
Thats what i want to know
login or register to post comments
backroompeon wrote :
I am sorry to see it gone . And I had been on
there earlier tonight .
Guess I'll hang out here then .
Who gives a flying f**k where it went. It's narrowminded
people are gone, at least for now, until they start making
trouble here or somewhere else . You know the ones, the die
hard fans of target. Targets cks was a corporate venture .

Read our feed
Target's lawyers are out and about issuing cease & desist
letters.
edit: More information - Our first Cease & Desist, courtesy
of Target
login or register to post comments
Target Sucks .. wrote:
I'm not bringing up p. 2 of Kerrys letter . My
machine or didn't it post?
Your machine, I suppose, as I can view it in its entirety and
I've heard no other complaints .
sleK Says: Assuming that you're the same "Target Sucks" that's been
rnu, 07/27/2006 - posting the AP Directives everywhere, could you explain the
11 51pm significance of them or explain why you appear rather hellbent
on keeping them in the public domain?
I don't understand either the relevance or the purpose and I
haven't been able to find a suitable explanation .
sleK Says :
Fn , 07/28/2006 -
12 33am
Ok, so it is just disclosure for the sake of disclosure .
Quote:
BTW : Thought you caved in ra ther quickly on
that .
Well, if there was some point to it I'd probably be willing to
help. But, as it appears that there's really no cause and
you're just stirring the pot to see the water go 'round,
there's no reason for me to get involved .
login or register to post comments
Quote :
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 19 of 29

login or register to post comme n ts
Fair enough, but surely you understand how unreasonable it
is to expect site ops', like myself, to support your apparent
grudge when faced with the costly prospect of litigation?
Quote:
It may have taken 3 yrs but Tarbutt is spending
some cash trying to put the genie back in the
internet bottle .
It's a beautiful thing . Once it's out there it's out there .
login or register to post comments
sleK Says :
Fri, 07/28/2006 -
6 52pm Quote:
I would only opine that it seems to say that
once info is published that is the end of
confidentiality .
That may be so but it doesn't dissolve liability.
IANAL, but it appears to me that an entity needs only to
establish the economic value of the information and
demonstrate "reasonable efforts to maintain the secrecy" of
the information before injunctive relief and damages can be
granted.
Quote:
Gee Slick, a 33 year old female ski bum ran
right over you I I I !
Is this addressed to me?
Look, I'm just trying to help as it's pretty clear that you
haven't the faintest clue about what you're getting yourself
into .
The simple fact is that you may end up in court, facing
whatever injunctive relief and damages that Target puts on
the table, should Target choose to pursue you . From
experience, I can tell you that it's not a fun place to be . But,
if you're intent on finding out for yourself, keep it up and
good luck.
Case 1:06-cv-02116-CC Document 1-1 Filed 09/05/2006 Page 20 of 29

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differential? EXHIBIT D
Forum topics
Posted by
Rockta ne
Put yourself in Target's place : one of your ex-employees has
posted on a website confidential proprietary information about
The Target Stores Employees' Web Site
Home » Forum N Workplace Issues » General Co nversation
Posted by Target Sucks - at 2006-07-28 08 : 38
This site is being monitored by the Faegre Benson law firm on behalf of Target Stores .
The screen name used is normally 'bunkl' and this person is Kerry L . Bundy of the law
firm of Faegre Benson 612 766 8217. kbundy@faegre .com .
He and his firm are monitoring this web site for anti Target activities .
FYI : http ://www.retail-worker.com/documents/20060727 .target cease_and_desist .pdf
and their web site is www .Faegre .com
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Posted by This is horrible news . I hope this site does not give up your
jollyrancher information . Shameful of them to even ask . It's one thing to ask
Fn, 2006-07-28 to have your post removed, but I'm sure there is some sort of
11 :08 privacy act . A million scurges on Mr . Bundy and Faegre Benson
Law firm.
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from union reps