There is no universal secrecy or proprietary-knowledge requirement.
Select evidence for the actual assertion
Show the relevant special or advanced knowledge using accurate examples. Confidentiality language in a contract does not itself establish specialized knowledge, and its absence does not automatically defeat the case.
Internal material the employer owns: the platform documentation, recipe and protocol libraries, training records showing how the knowledge is acquired and by how few, development history and investment, and a statement of how many staff worldwide hold it. The work is in retrieving configuration histories, locating who wrote which procedure, assembling training records, and getting a senior leader to write and sign a considered statement about how uncommon the knowledge is. Start with evidence that existed before the petition: training records, restricted technical material, version histories, project assignments, and letters explaining why comparable employees cannot simply take over. Choose records that show how the knowledge was acquired and applied: dated training materials, access records, process revisions, project notes and a supervisor’s specific explanation can each serve a different purpose. Sequence the evidence from pre-existing materials outward: internal manuals, version histories, training records, deployment tickets, customer requirements and declarations from knowledgeable supervisors.