Private fund managers have become highly attuned to the risks posed by theft of proprietary information and have been aggressive in seeking recourse against former employees who have attempted to misappropriate such information. See “Proprietary Trading Firm Sues Former Chief Operating Officer for Allegedly Misappropriating Confidential Information to Benefit His New Hedge Fund Manager Employer,” Hedge Fund Law Report, Vol. 6, No. 42 (Nov. 1, 2013). Federal and state authorities have, in many cases, added criminal charges to the civil efforts of managers. See “Recent Developments Affecting the Protection of Trade Secrets by Hedge Fund Managers,” Hedge Fund Law Report, Vol. 6, No. 41 (Oct. 25, 2013). A recently-filed action by a quantitative hedge fund manager against a former employee illustrates the difficulty of preventing theft of trade secrets – despite sophisticated legal and technological efforts – as well as the claims and remedies available to private fund managers and prosecutors in such circumstances.