Schering Chemicals v Falman Ltd [1981] 2 All ER 321

The action must be for damages and not simply for restraint. Damages may be claimed for breach of confidence (Seager v Copydex Ltd (No 2) (1969)) on a tortious basis, and considered analogous on the same basis for the conversion of goods (per Lord Denning). This will only be effective if the information has not yet been released and an injunction will be sought on a quia timet basis.