COLJI-Crim. 4-4:18

The elements of the crime of theft of trade secrets are:

1. That the defendant,

2. in the State of Colorado, at or about the date and place charged,

3. with intent,

4. to deprive or withhold from the owner thereof the control of a

trade secret, or to appropriate a trade secret to his [her] own use

or the use of another,

5. stole or disclosed a trade secret to an unauthorized person, or,

without authority, made or caused to be made a copy of an

article representing a trade secret.

[6. and that the defendant’s conduct was not legally authorized by

the affirmative defense[s] in Instruction[s] ___.]

After considering all the evidence, if you decide the prosecution has

proven each of the elements beyond a reasonable doubt, you should find

the defendant guilty of theft of trade secrets.

After considering all the evidence, if you decide the prosecution has

failed to prove any one or more of the elements beyond a reasonable doubt,

you should find the defendant not guilty of theft of trade secrets.