After 20 years of employment, Rowena Cheung quit her job with Fada International, an importer of jewelry and precious stones. She not only left the company with trade experience, but also an extensive rolodex of client contacts which she used to launch her own jewelry business. However, Cheung had signed a non-disclosure agreement (NDA) before leaving the company, in which she had promised not to disclose the customer information. Her former employer, in an effort to maintain its position in the competitive jewelry import business, then filed a lawsuit against Cheung claiming that she had misappropriated customer information.

As businesses continue to develop creative ways to monetize information in the digital age, friction has developed between the companies that create content and the companies that stand to profit from new models of distribution. In February, the United States District Court in New York addressed some of the basic issues faced by online media outlets when it issued a ruling in favor of the Associated Press (AP) in its lawsuit against online news aggregator All Headline News Corporation.