1993) was a case in which the U.S. Court of Appeals for the Fourth Circuit discussed legal tests for software copyright infringement, and ruled that trade secret misappropriation requires more than circumstantial evidence.

In 1988, they created a software group and expanded into Electronic Data Interchange with Claims Express, targeted at the medical industries, and EDI Link, designed to make and use a range of forms.

[2] The Fourth Circuit ruled that CTI did not meet their burden of proof because they did not indicate evidence from the trial that would have proven their point, therefore the district court's finding on copyright infringement claims were affirmed for the defendant.

The district court found that CTI's claimed trade secrets did not fulfill the requirements of deriving independent economic value from not generally being known and not being readily ascertainable.

On appeal, the court cited similar restrictions that were not deemed unreasonable in scope, and noted Hawkes' thorough knowledge of CTI's confidential information.