This is a legally tricky minefield. Depending on what is in summary, it -may- be subject to copyright but be protected as fair use... but a work being unpublished weighs against (but does not preclude) free use.
I could see an argument that it is a trade secret, too-- which could be used to oppose downstream dissemination.
I could see an argument that it is a trade secret, too-- which could be used to oppose downstream dissemination.