The actio servi corrupti presumably or possibly could be used to protect trade secrets and other similar commercial interests. That was not its purpose and was, at most, an incidental spin-off. But there is not the slightest evidence that the action was ever so used. In this regard the actio servi corrupti is not unique. Exactly the same can be said of many private law actions including those for theft, damage to property, deposit, and production of property. All of these could, I suppose, be used to protect trade secrets, etc., but there is no evidence they were. It is bizarre to see any degree the Roman actio servi corrupti as the counterpart of modern law for the protection of trade secrets and other such commercial interests. 19th century Trade secret law as known today made its first appearance in England in 1817 in Newbery v. James, and in the United States in 1837 in Vickery v. Welch. Trade secrets law continued to evolve throughout the United States as a hodgepodge of state laws. In 1939, the American Law Institute issued the Restatement of Torts, containing a summary of trade secret laws across states, which served as the primary resource until the latter part of the century. As of 2013, however, only four states—Massachusetts, New Jersey, New York, and Texas—still rely on the Restatement as their primary source of guidance (other than their body of state case law). It has also been recently theorized that the doctrine of trade secrets should protect competitively valuable, personal information of company executives, in a concept known as "executive trade secrets". Worldwide Commonwealth nations In Commonwealth common law jurisdictions, confidentiality and trade secrets are regarded as an equitable right rather than a property right. England and Wales The Court of Appeal of England and Wales in the case of Saltman Engineering Co Ltd v. Campbell Engineering Ltd held that the action for breach of confidence is based on a principle of preserving "good faith". The test for a cause of action for breach of confidence in the common law world is set out in the case of Coco v. A.N. Clark (Engineers) Ltd: The information itself must have the necessary quality of confidence about it; That information must have been imparted in circumstances imparting an obligation of confidence; There must be an unauthorized use of that information to the detriment of the party communicating