In what could be prove to be an important decision within the context of scraping of “public” data, in a recent case the Eleventh Circuit reversed a lower court’s dismissal of trade secret claims relating to the scraping of insurance quotes. (Compulife Software, Inc. v. Newman, No. 18-12004 (11th Cir. May 20, 2020)). The appellate court agreed with the lower court that while Compulife’s insurance quote database was a trade secret, manually accessing life insurance quote information from the plaintiff’s publicly web-accessible database would generally not constitute the improper acquisition of trade secret information. However, the court disagreed with the lower court in finding that the use of automated techniques to scrape large portions of the database could constitute “improper means” under state trade secret law. In reversing the lower court’s dismissal of the trade secret claims, the appeals court stressed that “the simple fact that the quotes taken were publicly available does not automatically resolve the question in the defendants’ favor.” Even though there was no definitive ruling in the case – as the appeals court remanded the case for further proceedings – it is certainly one to watch, as there are very few cases where trade secrets claims are plead following instances of data scraping.