Quantitative Trader Cutler Group, LP is looking for elite level quantitative gamers or quantitative analysts/traders to join their their Trading team in San.Entdecken Sie Glassdoor. Bei Glassdoor finden Sie Millionen von Jobs, Informationen zu Gehältern, Arbeitgeberbewertungen und Fragen aus Vorstellungsgesprächen — anonym gepostet von Mitarbeitern und Jobsuchenden. Finden Sie heraus, wonach andere heute auf Glassdoor suchen.Glassdoor has moved to dismiss all counts pursuant to Fed. R. Civ. a non-leader by name, Glassdoor decided that it would not be removed from the site. 3 violation of the Massachusetts trade secrets statute Mass. Gen.Recording conversations in the trading room We record the conversations in the trading room with contacts of clients in order to register proof of trades and to improve our services. This processing is necessary in view of ACT Commodities’ legitimate interest to be able to prove that an order was given for the transaction and to ensure the. Best fx broker. Before Justices Francis, Stoddart, and Whitehill MEMORANDUM OPINIONAppellant Glassdoor, Inc. The owner lacks tact and professionalism and has no business in the business world. Those developers said that they would not have accepted jobs with Andra if the recruiter had not “thoroughly explained the web posts,” and they said that they would not have sought out employment with Andra directly because of the Glassdoor web posts. Applicable Law and Standard of Review The legislature enacted Chapter 27 “to encourage and safeguard the constitutional rights of persons to petition, speak freely, associate freely, and otherwise participate in government to the maximum extent permitted by law and, at the same time, protect the rights of a person to file meritorious lawsuits for demonstrable injury.” Id. Chapter 27's main feature is a motion procedure that enables a defendant to seek the dismissal of frivolous claims and to recover attorneys' fees and sanctions. We conclude that Andra satisfied its § 27.005(c) burden.b. As we concluded above, the “claim” in this case is Andra's request for Rule 202 relief, not the potential claims Andra sought to investigate. op.) (party seeking Rule 202 deposition must provide evidence on which trial court can make finding); In re Campo, 2013 WL 3929251, at *1 (mandamus conditionally granted where no evidence was presented to the trial court at the hearing on the motion and party seeking Rule 202 deposition did not formally offer or admit its verified pleading at the hearing). 2005) (footnote omitted), we will consider the evidence in the clerk's record to resolve Glassdoor's second issue.4.Maintains a website on which it allowed people to post anonymous reviews of appellee Andra Group, LP as an employer. Andra filed a Rule 202 petition against Glassdoor seeking to discover the anonymous reviewers' identities. The trial court's order limited the deposition to these two posts, and it further purported to limit the deposition to the following statements within those posts: (i) Andra's hiring practices are illegal, (ii) Andra is violating labor laws, (iii) Andra is engaged in harassment based upon race and sexual orientation, (iv) illegal immigrants are working at Andra, and (v) Andra's supervisor Jorge is racist and sexist. Andra paid the recruiter approximately ,000 to recruit two additional developers. Did appellants establish a defense under § 27.005(d)? Appellants did not establish, or even argue, that the Rule 202 request was directly time-barred. However, in the case before us, unlike the cases cited above, the trial court's record contained numerous affidavits—a result of the Chapter 27 proceeding—in addition to the verified petition generally found in the record. Andra argues that appellants failed to preserve argument (iv) in the trial court.Glassdoor, joined by appellants Doe 1 and Doe 2, filed a Texas Civil Practice and Remedies Code Chapter 27 (anti-SLAPP) dismissal motion. Factual Allegations Andra's Verified Petition Requesting Deposition Before Suit alleged the following facts: Glassdoor operates a website that it describes as a free jobs and career website. Andra filed its Rule 202 petition on 17 August 2015, and the trial court signed its order on 18 February 2016.(2) Limitations and Special Damages Glassdoor argues that there is no benefit to allowing the deposition because (i) by the time of the first hearing, any defamation claims Andra might have had based on the two reviews were barred by the one-year statute of limitations and (ii) Andra produced no evidence of a direct pecuniary loss from the statements as would be necessary to support a business disparagement claim, which has a two-year limitations period. This means that the plaintiff must “ ‘establish pecuniary loss that has been realized or liquidated as in the case of specific lost sales.’ ” Id. KEETON, PROSSER AND KEETON ON THE LAW OF TORTS § 128, at 971 (5th ed. “Furthermore, the communication must play a substantial part in inducing others not to deal with the plaintiff with the result that special damage, in the form of the loss of trade or other dealings, is established.” Id. According to Lucente, Andra would not have incurred ,450 in recruiting expenses had the negative reviews been removed from the Glassdoor website. Appellants argue that they established that any potential claims based on the July and October 2014 reviews are time barred and so they were entitled to dismissal under § 27.005(d). Under § 27.005(d), appellants had to establish “by a preponderance of the evidence each essential element of a valid defense to the nonmovant's claim.” CIV. They argued only that the discovery sought offered Andra no benefit because any potential defamation claim would be time-barred. Andra specifically alleged that it did not anticipate any claims against Glassdoor.3. Additionally, the trial court's order states it considered “the pleadings, evidence, and arguments of counsel.” Mindful of the Texas Supreme Court's statement that when “all the evidence is filed with the clerk and only arguments by counsel are presented in open court, the appeal should b e decided on the clerk's record alone,” Michiana Easy Livin' Country, Inc. Because we reject appellants' lack of notice point even if we consider argument (iv), we need not decide whether appellants preserved that argument.5.The trial court denied that motion and granted in part the Rule 202 petition. Appellants assert that the trial court erred by (i) concluding that Chapter 27 did not apply and (ii) granting Rule 202 relief. The website offers access to “user-generated ․ ratings and reviews.”Negative comments about Andra were posted in ten anonymous reviews on the Glassdoor website. Andra responds that (i) Glassdoor has no standing to assert a third party's limitations defense, (ii) limitations for defamation may have accrued later than the first publication of the two reviews, and (iii) Andra's potential business disparagement claims are viable because it showed business losses of at least ,450. Costs incurred to disprove disparaging comments can also serve as special damages supporting a business disparagement claim. Additionally, Andra filed an affidavit by its president, Tomima Edmark, stating that 2015 was the first year in which Andra had to resort to recruiting agencies to fill job positions. We conclude that appellants did not establish a valid defense to Andra's Rule 202 petition. The two hearings in this case were non-evidentiary. Dist., 2014 WL 1407415, at *3; see also In re Noreiga, No. Glassdoor contends that the trial court took these statements out of context when it identified the five statements within the two reviews that justified the discovery.
Craft Beer Stellar, LLC v. Glassdoor, Inc. Civil Action No. 18.
Addressing the issues in reverse order, we conclude that (i) the trial court did not abuse its discretion by granting Rule 202 relief, and (ii) the trial court did not err by denying appellants' dismissal motion even if Chapter 27 applies to Rule 202 proceedings. One of the reviews was posted by someone who claimed to be an Andra interview candidate. Because the trial court could have concluded that the Rule 202 discovery's benefits outweighed its burdens based on either Andra's potential defamation claim or its potential business disparagement claim, Glassdoor had to demonstrate that both claims were not viable. Finally, Andra filed the affidavit of Thomas Tribble, who was one of the web developers Andra hired through a recruiter in 2015. Accordingly, they were not entitled to dismissal under § 27.005(d).3. In prior cases, we have stated that the party seeking Rule 202 deposition must provide evidence on which the trial court can make its finding, that evidence ordinarily must be presented to the trial court at the hearing, and that neither sworn or verified pleadings nor counsel's arguments are evidence. But it does not explain how the context of these statements makes them non-actionable.The others were posted by people who claimed to be current or former Andra employees. At least 15 days before the petition is heard, the petitioner must serve the petition and notice of the hearing “on all persons petitioner seeks to depose and, if suit is anticipated, on all persons petitioner expects to have interests adverse to petitioner's in the anticipated suit.” Id. The rule authorizes service by publication on “[u]nnamed persons described in the petition whom the petitioner expects to have interests adverse to petitioner's in the anticipated suit, if any.” Id. If the court grants Rule 202 relief, it must find that(1) allowing the petitioner to take the requested deposition may prevent a failure or delay of justice in an anticipated suit; or(2) the likely benefit of allowing the petitioner to take the requested deposition to investigate a potential claim outweighs the burden or expense of the procedure. For the reasons that follow, we conclude that the trial court could reasonably have concluded that Andra produced some evidence of business disparagement damages. He said that he was concerned about the negative reviews on the Glassdoor website and that he would not have pursued employment with Andra directly because of those reviews. Conclusion For the foregoing reasons, we overrule appellant's first issue. DISPOSITIONHaving overruled appellants' issues, we affirm the trial court's order denying appellants' dismissal motion and determining Andra's Rule 202 petition. Although Does 1 and 2 were not joined as parties, nor did they formally intervene in the case as such, they joined the dismissal motion to protect their claimed First Amendment rights to speak anonymously. A presuit deposition order is appealable if the discovery is sought from someone against whom suit is not anticipated. Although the reviews contain other statements that would probably be nonactionable opinion (“low pay, horrible benefits”) and hyperbole (“it[']s practically slavery in that warehouse”), we conclude that other statements in the reviews are statement of verifiable fact.The oldest review was dated 8 July 2014, while the newest was dated 30 June 2015. Procedural History Andra filed its Rule 202 petition on 17 August 2015. The petition must state either that the petitioner anticipates a suit in which the petitioner may be a party or that the petitioner seeks to investigate a potential claim by or against the petitioner. Accordingly, Glassdoor's argument that the trial court abused its discretion in weighing the benefits and burdens is unpersuasive.“Proof of special damages is an essential part of the plaintiffs' cause of action for business disparagement.” Hurlbut v. We conclude that this evidence supports the premises that (i) the negative reviews on Glassdoor's website caused some potential employees not to deal with Andra and (ii) Andra spent over ,000 to overcome the negative effects of the Glassdoor reviews. Glassdoor argues that Lucente attributed Andra's additional recruiting expenses to all ten reviews on which Andra sued and not just to the two reviews on which the trial court granted relief. V & C International reviews in Pickering. A free inside look at company reviews and salaries posted anonymously by employees. V & C International Reviews in Pickering, ON inIMC Trading reviews. A free inside look at company reviews and salaries posted anonymously by employees.See what employees say it's like to work at EDF Trading. Salaries, reviews, and more - all posted by employees working at EDF Trading.
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Log in to Glassdoor. Sign in to view job alerts, saved jobs, followed companies and more. Don't have an account? Sign up now.Glassdoor follows simple principles and guidelines to ensure the most authentic, transparent, and valuable information is available to workers and job candidates while balancing fairness to employers.Lek Securities Corporation is abroker-dealer based in New York, New York and is registered with the Commission. LEK provides market access to its customers, including Avalon and other foreign trading firms. LEK markets itself as the "Gateway to the Markets" by providing access to exchanges and other trading venues. The order limited the deposition to two specific reviews posted on Glassdoor's website, and it further purported to limit the deposition to five specific statements within those reviews. At the outset we note that Does 1 and 2 are unaffected by the trial court's order granting in part Andra's Rule 202 petition. The two reviews identified in the order were not reviews that Does 1 and 2 claimed to have written. That is, the trial court did not permit Andra to discover Doe 1's and 2's identities. The order also required Glassdoor to produce certain categories of documents. Because Doe 1 and 2 were not injured by the Rule 202 order, we conclude they lack standing to assert issue two.
Glassdoor, Mill Valley, California. 223,647 likes 494 talking about this. One of the world’s largest job and recruiting sites on a mission to help.Jump Trading reviews. A free inside look at company reviews and salaries posted anonymously by employees.Explore Glassdoor. Glassdoor has millions of jobs, salary information, company reviews, and interview questions – all posted anonymously by employees and job seekers. See what others are looking for on Glassdoor today. Andra also needed to know not only the reviewers' identities but also the facts and circumstances of the reviewers' relationships with Andra to evaluate potential defensive issues such as substantial truth. Did the trial court abuse its discretion by finding that the likely benefit of allowing the discovery outweighed the burden or expense of the procedure? The 22 October 2014 review was entitled “The company is run by a tyrannical woman who has zero compassion and zero ethics.” It contained the following text: Pros They are always hiring, but this is due to the turnover that results from low pay, horrible benefits, lack of organized training and poor treatment of the employees. She identified the ten negative reviews on the Glassdoor website and said that their publication resulted in Andra's getting a reduced pool of qualified job applicants. W.3d at 667–68 (discussing Supreme Court precedent). The October 2014 review contains the following statements:• “Hiring practices are illegal.”• “The company is violating labor laws ․”• “Harassment based on race and sexual orientation is a daily occurrence from the top down.”The July 2014 review contains the following statements:• “[T]he supervisor Jorge is racist and a sexist ․”• “[T]hey have illegal imm[i]grants working there ․”5We conclude that each review contains at least one disparaging statement of objectively verifiable fact. They are accusations of illegal conduct that are capable of being proved true or false. Its argument proceeds in the following steps:• The First Amendment protects the right to speak anonymously. Thus, Glassdoor's First Amendment argument does not show that trial court acted unreasonably or arbitrarily by ordering discovery that will disclose the two reviewers' identities.d. Issue One: Did the trial court err by denying appellants' Chapter 27 dismissal motion? We have already concluded that Andra produced some evidence of special damages. The petitioner bears the burden of producing evidence to support the necessary finding. Knowing the reviews' contents alone did not tell Andra whether it had viable claims against the anonymous reviewers. We also note that a Rule 202.1(a) petition seeks “to perpetuate or obtain ․ testimony ․ for use in an anticipated suit.” TEX. For these reasons, we disagree with Glassdoor's lack of notice argument.b. The 8 July 2014 review was entitled “Packer Interview,” and it contained the following text: Interview It sucked the owner and the management there are rude and very judge mental [sic] the supervisor Jorge is racist and a sexist its practically slavery in that warehouse they have illegal imm[i]grants working there that need the money so is willing to put up with the disrespect and little pay. Andra filed an affidavit by its human resources manager April Lucente. If they contain disparaging statements of objectively verifiable fact, this would support the trial court's finding that there is a likely benefit to allowing the discovery to proceed in investigation of Andra's potential claims. denied) (statement that a doctor confirmed that plaintiff had sexually molested someone was an objectively verifiable factual statement); see also Bentley v. The October 2014 review accused Andra of (i) violating labor laws and (ii) racial and sexual orientation harassment “from the top down.” These assertions are not examples of rhetorical hyperbole or mere personal opinion. Whether Andrea actually employed illegal immigrants is a matter of objectively verifiable fact. Finally, Glassdoor asserts that the First Amendment bars Andra's effort to discover the anonymous reviewers' identities. For the reasons already stated, we conclude that Andra produced evidence sufficient to raise a genuine fact issue that (i) it has a potentially viable business disparagement claim that is not time-barred and (ii) both reviews contain as least one disparaging statement that is a verifiable statement of fact. § 27.005(b).• If the movant carries its initial burden, the nonmovant must establish “by clear and specific evidence a prima facie case for each essential element of the claim in question.” Id. If the nonmovant fails to carry this burden, the trial court shall dismiss the legal action. § 27.005(b)–(c).• Even if the nonmovant carries its burden, the trial court shall dismiss the legal action if the movant establishes by a preponderance of the evidence each essential element of a valid defense to the nonmovant's claim. Second, appellants argue that the discovery carries no benefits because (i) any potential defamation claims would be time-barred and (ii) Andra's potential business disparagement claims were unsupported by evidence of special damages. Andra pled, “Andrea desires to obtain the testimony of Glassdoor to investigate potential claims for defamation or business disparagement.” (Emphasis added.) Andra further stated, “Andra does not anticipate any claims against Glassdoor, and only seeks to investigate potential claims by Andra against anonymous persons or entities who posted false and defamatory statements against Andra on Glassdoor's website (‘Potential Defendants').” Contrary to Glassdoor's argument, the reference to “Potential Defendants” is not significant because that term is at least as consistent with investigating “potential claims” as it is with preserving testimony for an “anticipated suit.”Glassdoor argues that Andra must have anticipated suit because Andra already had the contents of the reviews in question, Andra's petition alleged that the reviews contained false and defamatory statements, and “[t]he only information Andra sought to learn was the reviewers' identities.” But this is a non sequitur. App.—Dallas 2003, no pet.) (“[T]ruth, even substantial truth, is a complete defense to defamation.”). We thus conclude that the trial court did not act arbitrarily or unreasonably in not treating Andra's venue allegation as controlling. For the reasons that follow, we conclude that Glassdoor has not shown an abuse of discretion in either respect.(1) Additional Facts The following additional facts are pertinent to our analysis: The trial court limited the deposition to two reviews, which were dated 8 July and 22 October 2014. We proceed to examine the two reviews at issue under these principles. 2002) (speaker's assertions that, based on speaker's investigation, judge was corrupt were verifiable enough to support defamation claim). This too is not a matter of rhetorical hyperbole or personal opinion. Did the trial court abuse its discretion by ordering discovery despite the reviewers' First Amendment right to speak anonymously? 334, 342 (1995) (“[A]n author's decision to remain anonymous ․ is an aspect of the freedom of speech protected by the First Amendment.”).• This right must be balanced against the right of others to hold accountable those who engage in speech not protected by the First Amendment. Glassdoor's argument nevertheless fails because its fourth premise is not. If the trial court dismisses a legal action, it shall award the movant court costs, reasonable attorneys' fees, other expenses, and sanctions. Accordingly, the evidence of potentially actionable statements was “clear and specific.” See id.
Attorneys for Petitioner Glassdoor, Inc.: Seubert French Frimel & Warner LLP, William J. Epstein Attorneys for Real Party in Interest Machine Zone, Inc.: Arnold & Porter LLP, Michael A. MZ contends that in violation of a nondisclosure agreement signed by all MZ employees, Doe posted a review on Glassdoor's Web site disclosing confidential information concerning the RTPlatform technology. It is possible for a statement to be false in part but still to convey true information, and if the information thus conveyed is confidential, the statement can be found to violate a nondisclosure agreement even if it is in some respects false. (Glassdoor), operates a Web site on which workers can post “reviews” of past and current employers. (MZ) is a developer of software products including the online multiplayer game “Game of War: Fire Age.” During the pendency of this proceeding it has rebranded itself as “MZ” and has released a product labeled RTplatform, which it describes as “a standalone real-time platform technology that enables the exchange of data between billions of endpoints worldwide virtually simultaneously.” Prior to this rebranding, MZ brought suit against a former employee named fictitiously as John Doe. This is not to suggest that an employee can defeat such a suit merely by showing that his or her statements were in some part untrue.When Glassdoor refused to identify Doe, MZ moved for an order compelling it to do so. Glassdoor brought this petition for a writ directing the trial court to set aside its order. E.2d 534, 549 [“when a third-party entity, such as a newspaper, is subpoenaed to reveal the identity of an anonymous commenter who has used that third party as a forum for his anonymous speech, the third-party has standing to contest the subpoena under the principle of jus tertii”]; Pilchesky v. Here, however, MZ has never attempted to separate the portions of Doe's review that are “not literally accurate in all respects” from those that might have conveyed true, and confidential, information. Daftar broker forex di surabaya. We have concluded that MZ failed to make a prima facie showing that Doe's statements disclosed confidential information in violation of the nondisclosure agreement. BACKGROUNDAccording to the complaint, Doe posted the offending review on Glassdoor's Web site on or about June 21, 2015. An employer cannot establish a claim for breach of a nondisclosure agreement unless it is prepared to prove, and does prove, that the defendant disclosed actual confidential information, i.e., that his or her statements were, in some relevant degree, true.Entitled “A Scandal,” the review commences by identifying three “Pro's” of employment at MZ: “Free food, free massages, [and a] spacial [sic] office.” It then sets out four “Con's,” as follows:“1. Nothing in this record would sustain a finding that the CEO's statements—reported by Doe inaccurately, according to MZ—had this effect.Management spreads unreal information to both outside VC's and employees. 92, 95 [“The trend among courts which have been presented with this question is to hold that entities such as newspapers, internet service providers, and website hosts may, under the principle of jus tertii standing, assert the rights of their readers and subscribers.”]; In re Indiana Newspapers Inc. MZ's hesitation on this point may be understandable, because Doe's supposed disclosures do not cast MZ in a favorable light.
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We issued a stay, followed by an order to show cause why the requested relief should not be granted. Since neither party contests the point—and since John Doe can suffer no prejudice in light of our disposition—we treat it as established that he received adequate notice. 9 [dictum; standing not raised and not subject to determination sua sponte]; Trawinski v. If Doe had stated that MZ was laundering funds for a criminal syndicate, MZ might have a tort claim; but it would not have a claim for disclosure of confidential information unless the company was, in fact, laundering funds. Their contents are not “learn[ed]” or “disclosed,” but born of error, or perhaps malice, in the speaker's own mind. After one year has been passed, it's not verified by any other resources. Terrible work-life balance, except for the platform team, which do not know what to work on. MZ therefore failed to establish a prima facie case predicated on Doe's account of the CEO's statements. Since any confidential information disclosed in the review has now become publicly known, we asked for supplemental briefing on the question whether the review should remain sealed.For Data Science team and Game Engineering team, people usually go home after pm and have on-call duties every month.“4. The company has invested heavily in the platform team (there are 70-80 engineers). App.4th 1538, 1541 [“ ‘a nonparty ‘to civil litigation (such as a newspaper) [may] assert the constitutionally protected rights of an author to remain unknown’ ”]; Mc Vicker v. DISPOSITIONMZ has failed to make a prima facie showing that anything in Doe's review disclosed confidential information in violation of the nondisclosure agreement. In response, MZ conceded that the seal should be lifted.However, after one year, nothing has been done by that team. Let a peremptory writ issue directing respondent court to set aside its order of September 15, 2015, and issue a new order denying the motion to compel. Accordingly, we have ordered that the review and all other materials filed under seal in this matter be unsealed. IV, post, concerning the overbreadth of the original sealing order.2.
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With respect to breach, it contended that MZ had failed to establish that the review disclosed any information that was covered by the nondisclosure agreement. The cross-referenced statute, which is part of the Uniform Trade Secrets Act, requires the trial court to “preserve the secrecy of an alleged trade secret by reasonable means, which may include granting protective orders in connection with discovery proceedings, holding in-camera hearings, sealing the records of the action, and ordering any person involved in the litigation not to disclose an alleged trade secret without prior court approval.” (Civ. We have not overlooked Krinski's requirement that efforts be made to notify the speaker of the attempt to discover his or her identity.It emphasized that MZ had not specified which statements in the review were supposed to have revealed confidential information, nor the confidential information they supposedly revealed. App.4th 1154, 1163-1164 (Krinsky), citing Talley v. The issue receives little attention from the parties, and no declaration was submitted to establish the fact of notice.It also presented evidence that some of the more concrete statements in the review disclosed information that was already publicly available. Glassdoor petitioned this court for an extraordinary writ vacating the order and directing the trial court to deny the motion. State of the Law There is no question that Doe had a right, protected by the First Amendment, to speak anonymously. However the record includes an e-mail exchange in which counsel for Glassdoor told counsel for MZ that Doe had been notified. Instead it broadly alleged that Doe had “provided details concerning undisclosed technology Machine Zone has and is developing, the stage of development of that technology and the scope of Machine Zone's investment therein.” MZ further alleged that the post “quoted Machine Zone CEO Gabriel Leydon's confidential internal statements concerning that technology.”On July 2, Machine Zone promulgated a subpoena directing Glassdoor to produce a copy of Doe's review as well as information identifying its author. 334, 341-342 & Watchtower Bible and Tract Society of New York, Inc. In this regard its interests resemble those of a news outlet resisting disclosure of the identity of a confidential source.Glassdoor produced a copy of the review, but otherwise objected to the subpoena on the grounds, among others, that disclosure of the poster's identity would violate his “right to speak anonymously under the First Amendment,” and that Machine Zone had “failed to make a prima facie showing that any statement in the review ․ is actionable.” MZ filed a motion to compel. Its position differs only in that it does not, apparently, exercise any editorial control over the speech it publishes, acting instead as a passive conduit for the speech of others.It challenged Glassdoor's standing to assert Doe's First Amendment rights and argued that MZ had “made a sufficient showing to entitle it to disclosure of Defendant's identity.” MZ also moved to file the entire review under seal, asserting that the review “contains information that is confidential, non-public and competitively sensitive,” and that “[d]isclosure of this kind of confidential information is highly detrimental to Plaintiff and would cause Machine Zone competitive and irreparable business harm by providing competitors with insight into technology development and business plans at Machine Zone.”Glassdoor opposed the motion to compel, insisting that it had standing to object and arguing that MZ had not presented adequate evidence of either a breach of the nondisclosure agreement or of resulting injury. It is far from clear that this fact should deprive it of the status of a speaker seeking to protect its own First Amendment rights.4.