4.18.1832 Theft of Trade Secrets (Economic Espionage Act), 18 U.S.C. § 1832 See Statute

[Defendant] is charged with stealing trade secrets. It is against federal law to steal trade secrets. For you to find [defendant] guilty of this crime, you must be convinced that the government has proven each of these things beyond a reasonable doubt:

First, that [defendant] knowingly [stole; took without permission; copied without permission; downloaded without permission; received while knowing it was stolen or taken without permission] a trade secret;

Second, that the trade secret was related to or included in a product produced for or placed in interstate or foreign commerce;

Third, that [defendant] had the intent of economically benefiting someone other than the trade secret’s owner; and

Fourth, that [defendant] intended or knew that his action would injure the trade secret’s owner.

The term “trade secret” means all forms and types of financial, business, scientific, technical, economic or engineering information, including program devices, designs, prototypes, methods, techniques, processes, procedures, programs or codes, whether tangible or intangible, and however stored if the owner has taken reasonable measures to keep the information secret and if the information derives independent economic value, actual or potential, from not being generally known to or readily ascertainable through proper means, by the public.

The term “interstate commerce” means trade or travel from one state to another.