regarding the identification of its trade secrets the reasonable steps taken to maintain a secrecy and misappropriation of a strict racegoers e t c global there are several grounds for a verse so the our client martin beddoes declaration identify in telling players trade secrets and his identification of the trade secrets was obviously sufficient enough for a t c globo to find them in the shared his technology with another customer another client the industrial and commercial bank of china commonly referred to as i see he was also a customer of subject to the same license agreeing with the saying confidentiality provision and so when at the time that this was all presented  many specific details and points of a trade secret that in the reply a t c came back and said well those points are secret because here they are we found them in the i c c specification and adequately preserve the secrecy and confidentiality of our trade secrets and i believe that that does so you know one of the points that the court does that is your question your hon discovery under the california discovery statue involving trade secrets but in any event all we have to do is show that we have one great secret that we had adequately identified and that we had taken reasonable steps to maintain secrecy and that has been misappropriated and the judge in fact did find that we had identified some trade secrets and as far as secrecy is concerned you know we have overwhelming have been as of misappropriation we had a declaration from kevin murphy a former c e o and president of electronic transaction clearing a subsidiary of d t c global who said that it was common knowledge when he was there that the company was trying to copy the intel of clear system and to create and build their own system and our expert forensic expert who went in and compare the two systems barreto stated ad when during the transition period at the end of the license agreement where they had the two companies had to cooperate and make sure that data was  basically i just think that the judge jump to jump to judgment too quickly at the beginning of this case and that certainly identified enough issues genuine disputes as to material facts and let this go trade secrets it was difficult for a court just ruled muddle through the entire record here but you know initially we also bear in mind that their initial tracing or disclosure just made some very sweeping claims that they own you need but the logic and requires the plaintiff to separate out all of the trees secret information he says was just saying we own trade secrets in our software generally intel if they're certainly  license the information we provided to your honor and to the court below was not he too intelligent and it was not in connection with a license so this confidentiality provision has no applicability whatsoever to the information that we made there is hardly surprising given that it's axiomatic that in the district courts own words quote no amount of discovery propounded on defendant will uncover which elements of plaintiff's own intel of their system it will these are traits years in which are generally know tracers are if you goes without saying that the defendants don't know what the player's trade secrets are that's that's why we're here today your honor if this case is more than two years old now i still don't think that there's a single piece of information that intel  you need to amuse yourself mr order  still that you're still not hearing  that and there was nothing wrong with that and we were very specific and of meadows declaration you know if you read those paragraphs ten through twenty two it's very detailed and in fact we were so detailed and specific that e t c had no problem with my colleague boast that they were able to find in ten days everything we were talking about so it was adequate identification and then all of the problem is that they found that information in a source that was still protected so as a result we again this court does not have to decide who's right and who's wrong this court just has to decide whether it is a material issue and there's a genuine dispute as a material fact and so certainly there's no just stand right now actually that they seem to have conceded that we've identified the chase secret with sufficient particularity because they were able to then find the details further somewhere else  and somewhere else is protected so that secrecy is protected and again we showed enough evidence to show that there's been this verdict misappropriation d of those trade secrets so in conclusion i think that the district court erred that this another error that he committed but the main problem here is that on the november view there certainly are genuine issues of material fact requiring this to be sent back to the court district court for discovery and the trial before jury thank you thank you m unless either of my colleagues have questions for the advocates i'm just going to thank mr order and strophe for their ex one of the arguments so very honor very complicated case and the panel and more depth and issue an opinion and due course