I agree that they can get the data through other means. Not so sure about

> There are so many different players who have access to most or all of the data it would hard to prove it came any one source at all.

Because a prosecutor can obtain copies of all emails talking about this, they can examine your bank accounts for payments from data brokers, they can require legal to give them copies of any contracts, they can look at audit logs from the production database and airlines aren't Evil Inc -- stuff will inevitably leak and get out. You can't cover yourself that well as a CEO looking to make a quick buck...