I-Admin (Singapore) Pte Ltd v Hong Ying Ting [2020] SGCA 32 (a) What interests are sought to be protected by the cause of action? (b) What is the nature of the threat to these interests? (c) What are the remedies that ought to be made available where the relevant interests have been infringed? The protected interests 46 The answer to the first question can be gleaned from the history of the law of confidence. Early English jurisprudence reveals a longstanding tradition of protecting confidential information. By the early 19th century, confidentiality was safeguarded through a range of doctrines in contract and criminal law as well as the law of inheritance, common law copyright, patent law and the law of evidence (Tanya Aplin et al, Gurry on Breach of Confidence (Oxford University Press, 2nd Ed, 2012)) (“Breach of Confidence”) at para [2.01]). However, confidentiality was not, of itself, a basis for legal protection but only an indirectly protected interest (see Lord and Lady Perceval v Phipps (1813) 35 ER 225 at 229; Gee v Pritchard (1818) 36 ER 670 at 678). 47 Prince Albert v Strange (1849) 41 ER 1171 (“Prince Albert”) is widely regarded as one of the earliest cases that recognised the existence of an independent action for breach of confidence. Prince Albert sought injunctive relief to prevent the exhibition and publication of a catalogue that described etchings by himself and Queen Victoria. This was granted ex parte and the defendants failed in their attempts to have the injunction lifted. At first instance, Knight-Bruce VC grounded his reasoning in the common law protection of “property” (Prince Albert v Strange and others (1849) 64 ER 293 at 311). The unpublished etchings, being the “produce of labour”, were a kind of property and the common law “provided for their security, at least before general 22