reversal of a conviction in April 2012 by the United States Court of Appeals for the Second Circuit in United States v. Aleynikov In that case, it was held that the theft of the source code for a proprietary system at Goldman Sachs was never intended to be placed in interstate or foreign commerce. As Goldman had no intention of selling or licensing its system, § 1832 (as it was written at that time) did not apply. The provision was promptly amended on December 28, 2012 with the passage of the Theft of Trade Secrets Clarification Act of 2012, so that it now applies to products or services that are used or intended for use in interstate or foreign commerce. The amendment led to a conviction in United States v. Agrawal. Expansion of penalties On January 24, 2013, § 1831 was amended to increase the maximum fines: in the case of individuals, from $500,000 to $5,000,000, and in the case of organizations, from $10,000,000 to "the greater of $10,000,000 or 3 times the value of the stolen trade secret to the organization." Civil cause of action On May 11, 2016, in what Forbes called "the single most important intellectual property development since Congress enacted the America Invents Act," the Defend Trade Secrets Act () expanded the EEA's reach. In cases filed after that date: is replaced to provide for private civil actions, including (subject to appropriate safeguards) ex parte orders "providing for the seizure of property necessary to prevent the propagation or dissemination of the trade secret that is the subject of the action." Remedies available to the court include the granting of injunctions, awarding of damages (including treble damages in cases of wilful and malicious misappropriation) and the awarding of costs in cases where the claim was made in bad faith. is amended to provide for criminal fines to be the greater of $5,000,000 or three times the trade secret's value (including any reproduction costs that the holder of the trade secret has avoided). is amended to include in the RICO list of predicate offences signifying racketeering activity. is amended to provide for whistleblower protection for an individual who makes a confidential disclosure to a government official in cases of a suspected violation of the law, or files a sealed document to the court with respect to an antiretaliation lawsuit. As a reinforcing measure, employers are required to include