PhoneDog v. Kravitz, No. 11-03474 (N.D. Cal. Nov. 8, 2011), was a case in the United States District Court for the Northern District of California about whether Twitter accounts and their passwords could be company property or trade secrets. In this case a mobile device news website PhoneDog sued Noah Kravitz, its former employee, after Kravitz refused to turn over password information for the Twitter account he developed and cultivated during his employment. When Kravitz asked the court to dismiss this case, the court held that Twitter accounts and their passwords (as described by PhoneDog) could constitute trade secrets and that failure on behalf of the employee to relinquish an account could constitute misuse of a trade secret or "trade secret misappropriation." This case is often cited