This case is often cited in arguments for the importance of including clauses about social media account ownership in employment contracts.

PhoneDog ran a farewell video post in which viewers are directed to follow Kravitz via the new @noahkravitz handle.

CUTSA defines a trade secret as "information, including a formula, pattern, compilation, program, device, method, technique, or process, that: 1) Derives independent economic value ... from not being generally known to the public ... and 2) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.

"[5] in accordance with these definitions, PhoneDog identified its trade secret as the passwords and other information associated with all @Phonedog_NAME Twitter accounts.

"[5] The district court held that Kravitz's refusal to relinquish his access to his Twitter account could constitute misappropriation.

On January 8, 2012, PhoneDog submitted a revised set of claims establish that the harmed relationships were: 1) 17,000 Twitter users as well as the merchants; and 2) Kravitz was operating as an agent of PhoneDog in operating the Twitter account and thus had a duty that was not met and thus resulted in negligent interference.

[4] PhoneDog claimed that Kravitz committed intentional interference with their business (or their "prospective economic advantage") by using confidential information to disrupt their relationship with their customers.

"[6] PhoneDog argued that its relationship with three entities were harmed: 1) 17,000 Twitter users; 2) Current and prospective advertisers; and 3) CNBC and Fox News.

"[6] Kravitz argued that PhoneDog did not establish that they owned the Twitter account, but the court held that "the nature of [the] claim is at the core of this lawsuit and cannot be determined on the present record.

Eric Goldman, a writer for Forbes, argued that "the law assumes that social media accounts have only two states: personal or not-personal.

Instead, social media accounts fit along a continuum where the endpoints are: 1) completely personal; and 2) completely business-related–but many employees' social media accounts (narrowly construed, ignoring the statutory overbreadth problem) fit somewhere in between those two endpoints.