PA Department of Revenue v. Tellerinio — Lottery Ticket VIRN Numbers Are Trade Secrets Exempt from Right-to-Know Disclosure Even After Prize Claims
The Commonwealth Court reversed the Office of Open Records and held that Pennsylvania Lottery ticket VIRN numbers (Validation Information Record Numbers) are trade secrets exempt from Right-to-Know Law disclosure under Section 708(b)(11), even though individual numbers are revealed to winning ticket holders at the time of claiming a prize. The court reasoned that compiling thousands of claimed VIRN numbers produces a recognizable pattern from which Scientific Games’ proprietary validation algorithm could be reconstructed — making the aggregated dataset a trade secret that ‘reveals’ the algorithm even if isolated numbers do not.