This Law Firm Publication by Epstein Becker & Green, P.C. discusses 21st Century Systems, Inc. v. Perot Systems Government Services, Inc., in which Perot Systems alleged that 21st Century Systems conspired to steal trade secrets. Perot Systems was awarded monetary damages for loss of goodwill, but the Virginia Supreme Court overturned this award because of insufficient evidence to establish value. Perot Systems relied solely on its actual sale to Dell, Inc., rather than comparing its loss of goodwill to the loss experienced by comparable businesses at the time they were sold.