Trade Secrets under Review: A Comparative Analysis of the Protection of Trade Secrets in the EU and in the US

摘要

Whereas in the US, rather uniform statutory protection on trade secrets was issued some 30 years ago, in the EU the rules on this issue have lacked common legal ground. This is likely to change soon, with a proposal for an EU directive on the protection of trade secrets. This article will examine this proposal, above all by comparing it to the current US regime on the matter. As the article will demonstrate, no statute is perfect, and neither is the EU's proposal.