Recently, a New York state court ruled that plaintiffs who claim trade secret misappropriation must identify the trade secrets during discovery. While federal courts in New York state have held that plaintiffs must identify the allegedly misappropriated trade secrets, there is relatively little state case law on the issue. Implicit in the decision is the court's holding that it is not enough, in the case of software source code, to merely identify the portions of the code that are not trade secrets.