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41. The cross-examination of PW1 would show that most of the confidential data is stored in plaintiff company's computer system and its cloud servers. Some of the confidential data is in the form of printout kept in the files in the office. Regarding the physical security measures taken to protect the confidential data till 2021, PW1 deposed that physical security measures include taking back of company assets from the employees who have left at the time of relieving. He further deposed that the electronic data was difficult to secure. Plaintiff has avoided to disclose what specific precautions were taken by it to guard its electronic data and also in what manner was it accessed by its employees. PW1 has deposed that confidentiality of information was conveyed to employees orally.