Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 4601 (2026)

Definitions

✓ current as of May 2026
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(Cite as: 9 V.S.A. § 4601)
Notes of Decisions
Cited in 16 cases (5 in the last 5 years), 1999–2025 · leading case: Zemco Mfg., Inc. v. Navistar Int'l Transp. Corp., 759 N.E.2d 239 (Ind. Ct. App. 2001).
Zemco Mfg., Inc. v. Navistar Int'l Transp. Corp., 759 N.E.2d 239 (Ind. Ct. App. 2001). “9 V.S.A. § 4601(3). 7 . The definition of "trade secret" in Kansas is also identical to Indiana's.”
Mobile Med. Int'l Corp. v. United States, 95 Fed. Cl. 706 (Fed. Cl. 2010). · cites it 2× “9 V.S.A § 4601(3) (2009); see also Dicks v.”
Dicks v. Jensen, 768 A.2d 1279 (Vt. 2001). “9 V.S.A. §4601(3)(B). See also McClary v.”
Omega Optical, Inc. v. Chroma Tech. Corp., 800 A.2d 1064 (Vt. 2002). “Rather, its definition merely parallels the first part of our statutory definition.”
Schwartz v. Frankenhoff, 733 A.2d 74 (Vt. 1999). “, 9 V.S.A. § 4601(3) (defining “trade secret” as “information, including a formula” that derives actual or potential economic value from not being generally known to or readily ascertainable by others using proper means and is subject to reasonable efforts to maintain secrecy)…”
Michael Long, Lynn Martin, Steven Goodkind & the Coalition for a Liveable City v. City of Burlington & BTC Mall Assocs., LLC, 199 A.3d 542 (Vt. 2018). “9 V.S.A. § 4601(3). 10 Like the trial court, we reject the argument that a court must review the unredacted document in camera (meaning privately in chambers) before considering whether the information is exempt.”
Concepts NREC, LLC v. Qiu (D. Vt. 2025). · cites it 4× “9 V.S.A. § 4601(2). And even if, as Defendants argue, reviewing a pirated copy of the Concepts software would not expose its underlying source code, source code is not the only potential trade secret contained within the Concepts software.”
True Velocity Ammunitions, LLC v. SIG Sauer, Inc. (D. Vt. 2024). · cites it 3× “Pending before the Court is SIG Sauer’s motion to dismiss in which it argues lack of standing, lack of personal jurisdiction, improper venue, and failure to state a claim.”
State v. Tiktok (Vt. Super. Ct. 2025). · cites it 2× “§ 315–320, and the definition of trade secret in the Trade Secrets Act (TSA), 9 V.S.A. §§ 4601–4609. So, if it is a trade secret under the PRA or TSA, it is exempt from public access under Vt.”
In Re: Manchester Square Partners, L.P. (Vt. Super. Ct. 2012). · cites it 2× “Vermont’s law on trade secrets, 9 V.S.A. § 4601 et seq., is designed to protect businesses from involuntary disclosure of confidential business information that could do financial harm if made public.”
Grand Circle LLC v. Rand (Vt. Super. Ct. 2005). · cites it 2× “The plaintiff, VBT Bicycling Vacations, has sued the defendants, Susan Rand and Sojourn Active Vacations, for misappropriation of trade secrets, 9 V.S.A. §§ 4601–4609; breach of fiduciary duty; tortious interference with business relations; breach of loyalty; and unfair…”
Concepts NREC, LLC v. Qiu (D. Vt. 2025). “Whether and to what extent Plaintiff’s claim for breach of common law duty of loyalty is pre-empted by the Vermont Trade Secrets Act, 9 V.S.A. §§ 4601–09. See Dicks v. Jensen, 172 Vt.”
Vt. Stat. Ann. tit. 09, § 4601(2): 1 case
Concepts NREC, LLC v. Qiu (D. Vt. 2025). “9 V.S.A. § 4601(2). And even if, as Defendants argue, reviewing a pirated copy of the Concepts software would not expose its underlying source code, source code is not the only potential trade secret contained within the Concepts software.”
Vt. Stat. Ann. tit. 09, § 4601(2)(A): 1 case
True Velocity Ammunitions, LLC v. SIG Sauer, Inc. (D. Vt. 2024). “Pending before the Court is SIG Sauer’s motion to dismiss in which it argues lack of standing, lack of personal jurisdiction, improper venue, and failure to state a claim.”
Vt. Stat. Ann. tit. 09, § 4601(3): 11 cases
Zemco Mfg., Inc. v. Navistar Int'l Transp. Corp., 759 N.E.2d 239 (Ind. Ct. App. 2001). “9 V.S.A. § 4601(3). 7 . The definition of "trade secret" in Kansas is also identical to Indiana's.”
Mobile Med. Int'l Corp. v. United States, 95 Fed. Cl. 706 (Fed. Cl. 2010). “9 V.S.A § 4601(3) (2009); see also Dicks v.”
Schwartz v. Frankenhoff, 733 A.2d 74 (Vt. 1999). “, 9 V.S.A. § 4601(3) (defining “trade secret” as “information, including a formula” that derives actual or potential economic value from not being generally known to or readily ascertainable by others using proper means and is subject to reasonable efforts to maintain secrecy)…”
Michael Long, Lynn Martin, Steven Goodkind & the Coalition for a Liveable City v. City of Burlington & BTC Mall Assocs., LLC, 199 A.3d 542 (Vt. 2018). “9 V.S.A. § 4601(3). 10 Like the trial court, we reject the argument that a court must review the unredacted document in camera (meaning privately in chambers) before considering whether the information is exempt.”
Concepts NREC, LLC v. Qiu (D. Vt. 2025). “9 V.S.A. § 4601(2). And even if, as Defendants argue, reviewing a pirated copy of the Concepts software would not expose its underlying source code, source code is not the only potential trade secret contained within the Concepts software.”
Vt. Stat. Ann. tit. 09, § 4601(3)(B): 3 cases
Dicks v. Jensen, 768 A.2d 1279 (Vt. 2001). “9 V.S.A. §4601(3)(B). See also McClary v.”
Omega Optical, Inc. v. Chroma Tech. Corp., 800 A.2d 1064 (Vt. 2002). “Rather, its definition merely parallels the first part of our statutory definition.”
Concepts NREC, LLC v. Qiu (D. Vt. 2025). “9 V.S.A. § 4601(2). And even if, as Defendants argue, reviewing a pirated copy of the Concepts software would not expose its underlying source code, source code is not the only potential trade secret contained within the Concepts software.”
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