made clear that the UTSA did not affect (1) contractual remedies, (2) civil remedies not based on trade secret misappropriation, or (3) criminal remedies, which may otherwise be of use to the aggrieved party. Section 8 stated the goal of making trade secret law uniform among states enacting the UTSA. Section 9 provided a short title to refer to the act and section 10 described the severability of the act. Sections 11 and 12 provided a date when the act took effect and the opportunity to explicitly list other acts to be repealed. Adoption by U.S. states , the UTSA has been adopted by all states except New York and North Carolina (but its law is very similar and seems to borrow heavily from the act ). On May 2, 2013, Texas enacted Senate Bill 953, becoming the 47th state to adopt the UTSA. The Texas statute took effect on September 1, 2013. Massachusetts adopted the Uniform Trade Secrets Act effective October 1, 2018. The UTSA has also been adopted in the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. States are not required to pass the act exactly as is, and some have made amendments. Notable cases The following cases have directly referenced the UTSA: Rivendell Forest Prods. v. Georgia-Pacific Corp. (10th Cir. 1994) Comprehensive Techs. Int'l v. Software Artisans, Inc. (4th Cir. 1993) DVD Copy Control Association v. Bunner (Cal. App. 1994) Ajaxo v. E*Trade Financial Corp. (Cal. App. 2010) Silvaco Data Systems v. Intel Corp. (Cal. App. 2010) R.C. Olmstead, Inc. v. CU Interface (N.D. Ohio 2009) Justmed v. Byce (9th Cir. 2010) Decision Insights, Inc. v. Sentia Group, Inc. (4th Cir. 2011) Cypress Semiconductor Corp. v. Superior Court (Cal. App. 2008) NCR v. Warner (S.D. Ohio 2008) Othentec v. Phelan (4th Cir. 2008) Southern Nuclear Operating Co. v. Elec. Data Sys. Corp. (11th Cir. 2008) International application Trade secret law varies more from country to country. The North American Free Trade Agreement (NAFTA) has provisions providing for uniform minimum standards for protecting trade secrets. Trade Secrets in Europe are dealt with on a country-by-country basis. In England and Wales, trade secret protection is predicated upon the common law concept of "breach of confidence"—i.e., regardless of the existence of a contract, those who obtain the trade secret in confidence shall not take unfair advantage of it without consent. Germany's Act Against Unfair Competition states, "any