I-Admin (Singapore) Pte Ltd v Hong Ying Ting [2020] SGCA 32 suffered so long as a defendant’s conscience has been impacted in the breach of the obligation of confidentiality. Threat to the interest 54 A question that follows is whether there is a threat to this wrongful loss interest that warrants a more robust response by the law. The elements of breach of confidence set out in Coco explicitly protect the wrongful gain interest. Although there is often a degree of overlap, it may not always be the case that a defendant’s conduct will affect both the wrongful gain and wrongful loss interests. This is exemplified by the facts of the present appeal. It was not proven that the respondents directly profited from their use of the appellant’s confidential materials. However, this does not detract from the fact that the respondents knowingly acquired and circulated these materials without consent. As submitted by Mr Lee, such conduct would have affected the respondents’ conscience, invoking the wrongful loss interest, because it was known that the relevant materials had been subject to an obligation of confidence. 55 This illustrates a significant and unchecked threat to the wrongful loss interest. The vulnerability of this interest is magnified when considered against the backdrop of advances in modern technology. It is now significantly easier to access, copy and disseminate vast amounts of confidential information. This can be done almost instantaneously, often without the knowledge of plaintiffs. As in the present case, employees will often have access to large volumes of confidential business material for the purposes of their employment. If at some point they were to proceed to surreptitiously download this information for their personal use or to start a competing business, employers are likely to be none the wiser for a considerable time. It is nearly impossible in these situations to safeguard information from all potential wrongdoing. The fragility of such 26