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CA Vs. MA In Battle Over Non-Compete Clause

Posted by kdawson on Tue May 05, 2009 05:42 PM
from the so-free-you-can-choose-bondage dept.
Lucas123 writes "A case was filed with superior courts in California and Massachusetts involving a former EMC top executive who is trying work for HP. The case is throwing into relief Massachusetts's and California's differing approaches to non-compete clauses in employment contracts. California courts have argued that non-competes hamper a person's ability to traverse the marketplace freely for work, while Massachusetts courts say the agreements actually afford freedom to develop technology without the fear of IP theft."
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  • Hey (Score:5, Informative)

    by ta bu shi da yu (687699) on Tuesday May 05 2009, @05:45PM (#27839229) Homepage

    In Australia, non-compete clauses are classed as restraint of trade, and thus illegal. Sucked in ex-EMC executive!

    • Re:Hey (Score:5, Insightful)

      by evilbessie (873633) on Tuesday May 05 2009, @06:04PM (#27839445)
      However if a company wanted you to take 6 months paid leave before you could leave I have no problem. But once you stop paying me you stop telling me what to do, that's mostly the way employment works.
    • Re:Hey (Score:5, Informative)

      by HalfFlat (121672) on Tuesday May 05 2009, @07:52PM (#27840441)

      In Australia, non-compete clauses are classed as restraint of trade, and thus illegal.

      This is, as far as I know, not true. Non-compete clauses are legal, but not universally regarded as valid — they are evaluated on a case-by-case basis. Here is an interview [bnetau.com.au] with Peter Townsend [townsendslaw.com.au], a lawyer specialising in business law, describing the state and enforceability of these clauses in Australia.

  • IP (Score:5, Funny)

    by Gat0r30y (957941) on Tuesday May 05 2009, @05:51PM (#27839297) Homepage Journal
    It seems IP doesn't only belong to the company- but also at least to some degree to the person who actually developed said IP. As it is located in his/her intellect and it is sort of difficult to remove without destroying it.
    Not that this argument about IP works in the first place - this guy is an executive.
    • Re: (Score:3, Funny)

      by BGrif (1190941)
      Can someone tell me how people can use IP freely?

      You know someone was going to do it!
      • Re:IP (Score:4, Funny)

        by martin-boundary (547041) on Tuesday May 05 2009, @07:53PM (#27840447)
        No, no, that's not how Bart would do it. [snpp.com]

        Bart: "Is Mister Freely there?"

        Moe: "Who?"

        Bart: "Freely, first initials I. P."

        Moe: "Hold on, I'll check. Uh, is I. P. Freely here? Hey everybody, I. P. Freely! Wait a minute... Listen to me you lousy bum. When I get a hold of you, you're dead. I swear I'm gonna slice your heart in half."

        • Re: (Score:3, Interesting)

          by tomhudson (43916)

          Since your former employer (unless they're SUN) doesn't own the IP to MySQL, it's not an issue. They can't claim ownership of your knowledge of MySQL since MySQL is already owned - by someone else - and the license that governs ownership of that knowledge is the license between YOU and MySQL (the gpl) unless your former boss had a separate agreement with MySQL that granted THEM ownership rights, which I seriously doubt, seeing as SUN bought them. Ditto for your other examples. What they DO own is the propr

  • by techno-vampire (666512) on Tuesday May 05 2009, @05:59PM (#27839373) Homepage
    To some extent, both positions are right. To me, the problem is in how broadly do you define competitor. As an example, let's say I was doing graphics work for an MMORG. Clearly, working for a different MMORG would be working for a competitor. Working on CGI for an animated feature wouldn't be, at least to me. Would working for a different company bringing out a first person shooter, or turn based strategy game be working for a competitor? Personally, I wouldn't think so, but again, that could be argued either way.
    • by evilbessie (873633) on Tuesday May 05 2009, @06:07PM (#27839469)
      No. Once you stop paying me you don't have any right to tell me what to do. You don't want me to join a competing company for say a year, you can damn well pay me for a year to sit on my ass. I'm fairly sure that they are not allowed in the UK anyway, so I'm fine.
    • by Libertarian001 (453712) on Tuesday May 05 2009, @06:58PM (#27840009)
      Companies have no business telling people where they can and cannot work. Don't want to risk losing your people? I guess that means you value them. Maybe try not treating them like shit and then you won't lose them.
        • Re: (Score:3, Informative)

          by ishobo (160209)

          The government has limited business telling people what they can and cannot agree to in a contract.

          There are many statutory rights you cannot invalidate with a contract.

          Here are some examples in California:

          1) Your landlord cannot put a clause in your rental/lease agreement that they can enter the property at anytime to check its condition.

          2) An employer cannot place conditions on a severance in regards to suing for back wages or filing a complaint to the state.

          3) Because California is a no-fault divorce state, both pre and post nuptials cannot use faults of character or behavior as conditions.

      • by AK Marc (707885) on Tuesday May 05 2009, @07:16PM (#27840161)
        No fair signing the contract, taking the money and then crying about it later when you are expected to live up to the contract.

        In CA, they put non competes in contracts all the time, even though they are essentially illegal (and anyone writing them in CA knows that). You can force "non compete" in that someone may not take something owned by the previous company, like a product or such, and use that at the new company for a competitive advantage. An illegal contract does not need to be honored. You can't sign yourself into indentured servitude. And a contract that specifies you can't work in the field you are most qualified in is not much different. That the companies like to have them to badger former employees with illegal contracts is all find and dandy. But in some areas, you aren't given a choice. You sign, or you starve (figuratively). So, you sign and expect the illegal contract to not be enforced.

        On the other hand, companies are so willing to throw employees under the bus today that it is ridiculous to think they can interfere with you taking another job by claiming "IP" issues.

        The company isn't claiming IP. MA is. MA claims that forced unemployment is ok because the risk that someone might accidentally share info with a competitor is too high. CA says that forced unemployment is illegal regardless of contract, just like indentured servitude is.
      • Re: (Score:3, Interesting)

        by corbettw (214229)

        That's apples and oranges (no pun intended). It's one thing to bring your knowledge with you, but bringing work product along should be strictly verboten. Your current employer paid you to create those items, it would be unethical to give them to someone else.

  • The right to work. (Score:3, Insightful)

    by Bellegante (1519683) on Tuesday May 05 2009, @06:05PM (#27839457)
    The freedom to seek gainful employment should not be infringed.

    While not a specifically enumerated right of the people, it is both expected that we work in a productive manner, and beneficial to the society in which we live.

    The only way I could possibly agree with the enforcement of such a contract would be through compensation - have them pay his salary for each of the 12 months they expect him to be employed.

    Even then, it deprives society of the good work he could be doing. Why should the government agree to such a thing?
    • Re: (Score:3, Interesting)

      by caitsith01 (606117)

      The freedom to seek gainful employment should not be infringed.

      While not a specifically enumerated right of the people, it is both expected that we work in a productive manner, and beneficial to the society in which we live.

      The only way I could possibly agree with the enforcement of such a contract would be through compensation - have them pay his salary for each of the 12 months they expect him to be employed.

      Even then, it deprives society of the good work he could be doing. Why should the government agree to such a thing?

      I think confidentiality is a better concept to employ in this scenario than blanket non-compete clauses. I.e., fine, work for whoever you want, but your previous employer should (and does, at least in Australia) have a right to require you to keep secret any confidential information you gained during the course of your employment with them.

      I am no fan of governments or companies controlling my life either. But I can see that there is a bargain to be made whereby you are paid to work on potentially sensiti

      • Re: (Score:3, Insightful)

        Suppose someone were going to pay me 2 years worth of money, up front, for 1 year of work, in exchange for not competing for a year.

        That's not how it works. They pay you market rate for doing your job (possibly a bit above to make you leave). It certainly isn't twice as much or (years worked+noncompete term)/(years worked) extra.

        That's really the problem.

  • by timeOday (582209) on Tuesday May 05 2009, @06:07PM (#27839473)
    It appears most of EMC is technically "located" in foreign tax havens [transnationale.org] (click Locations & Production). As such, I don't think the US Justice System should waste US taxpayer money enforcing EMC contracts. They like the low taxes in the Bahamas and Bermuda, let's see them protect EMC.
    • by Speare (84249) on Tuesday May 05 2009, @06:41PM (#27839823) Homepage
      Do you really want to go down the "you only get the legal protections you pay for" road? Libertarianism is strong on this site, but let's just say... there are some pretty rich players who don't have your best interests at heart.
  • by NeutronCowboy (896098) on Tuesday May 05 2009, @06:43PM (#27839853)

    Because that's what it really amounts to. Spend more than a few years at a company, get really good at what you do. Then, if the company pisses you off, you are faced with three options:
    1) Bend over and take it.
    2) Completely change your profession, and start from scratch. All knowledge you have acquired has been rendered useless.
    3) Be unemployed for the term of the non-compete.

    Alright, so it isn't quite slavery. You're not caned if you stop working for the master. But it's a damn risky proposition to actually stand up to any abuse.

    Is any more proof necessary that overzealous IP laws will strangle our economy? As someone else pointed out, Silicon Valley is Silicon Valley because talent is free to move between companies.

      • Re: (Score:3, Insightful)

        How about getting a job with a company that does not compete? How about the similar job for a company in a different line of business?

        The more highly educated and specialized you become, the more likely it is that the situation you describe simply doesn't exist.

        I can say with a high degree of probability, my skills and experience pretty much lock me into the industry I am now, and given the diverse areas in which my company does work, anyone who would hire me could be considered a competitor.

        It's not re

  • by PDG (100516) <pdg@webcrush.com> on Tuesday May 05 2009, @07:03PM (#27840063) Homepage
    I work for a California company, and they had me sign a non-compete. I asked them why considering that California courts will not enforce them. Response from the legal department--just in case the court changes their mind.
    • Re: (Score:3, Insightful)

      They do it to intimidate you, even though they know that they're not legally binding. Also, companies that operate in multiple states will try to impose terms of employment that can be enforced in whichever states are most anti-employee. If they're not enforceable somewhere else, they hope the employee won't realize that.

      They really should be abolished nationwide. It's just another way of asserting control over you even when you're receiving no compensation for the restrictions they're forcing on you.
    • Re: (Score:3, Interesting)

      I work for a California company, and they had me sign a non-compete. I asked them why considering that California courts will not enforce them. Response from the legal department--just in case the court changes their mind.

      Wouldn't the law at the time of the signing apply?

    • Re: (Score:3, Informative)

      But which is more important? Or actually: which state really has jurisdiction in this case?

      Probably the State in which the contract was executed or otherwise specified in the contract.

    • by Anonymous Coward on Tuesday May 05 2009, @06:05PM (#27839451)

      Ask yourself this: which state has Silicon Valley? Which state is home to the vast majority of tech companies?

      And which state is known for overreacting to animated LED characters by deciding they're bombs and evacuating the state capital over them?

      By the way, this has already been answered in a previous Slashdot article. Someone has done the research: California's lack of non-compete agreements helped them become a center of technology in the US. Massachusetts' non-compete agreements helped ensure that no tech company prospered there. (The only company I can think of that was based in Massachusetts is Digital, and they died what, over a decade ago?)

        • Re: (Score:3, Insightful)

          by Grishnakh (216268)

          Everyone here knows lots of tech companies that are located in Silicon Valley and elsewhere. As for Massachusetts, can you please list some? Other than perhaps EMC, I can't really think of any offhand. And no, MIT doesn't count, since it's a school.

          Maybe you're the retarded one, since you like to throw terms like that around.

          • by acomj (20611) on Tuesday May 05 2009, @06:37PM (#27839755) Homepage

            Lots of companies. Although since the PC beat the mainframe there are fewer computer companies.

            We have large offices for Raytheon, Parametrics, Solidworks, Comverse, Sigmatel, ..... uswusf.

            All the major "California" companies have large offices here in MA too:
            Sun/Oracle
            Microsoft
            Lotus/IBM
            Hp
            Symantec
            Akami

            In cambridge/boston its more Biotech (Amgen Novartus, pfizer )etc...

            google is your friend

      • by Xtifr (1323) on Tuesday May 05 2009, @06:23PM (#27839607) Homepage

        I'm almost always in favor of more open markets over regulation and control, so, IMHO, non-competes are stupid and a restraint of fair trade.

        Sounds a little self-contradictory there. The non-compete was not part of "regulation and control"; it was part of a contract negotiated supposedly in good faith by both parties in an open employment market. If you think non-compete's are a restraint of fair trade, then I suppose your head asplode, because it's the regulations that forbid them and nothing else. Only government regulation is supporting fair trade here, not the open market.

        Of course, those of us who aren't ideological fanatics and who realize that governments of the people are the only thing standing between us and outright slavery by corporate/military/religious/political overlords aren't a bit surprised. Governments that are too big or too small both lead to slavery, and finding a reasonable balance in between is almost impossible, which is why the phrase 'Situation Normal, All F***ed Up' was coined. :)

    • by BGrif (1190941) on Tuesday May 05 2009, @05:53PM (#27839305)

      otherwise what the hell are you supposed to do, work at burger king?

      I hear Burger King has really strict IP rules around the secret to why "The King" is so creepy.

    • by Hatta (162192) on Tuesday May 05 2009, @06:01PM (#27839405) Journal

      Easy solution. Legalize non-competes, but require the company to pay the employee while bound by the non-compete.

      • by b4upoo (166390) on Tuesday May 05 2009, @06:14PM (#27839545)

        Florida pretty much does what you state. Generally the non compete clauses only hold water as long as the person remains employed. I do not know how a large lay off payment would effect this practice.
                    The general idea being that a contract must continue to benefit both parties. When the employee is no longer paid the no compete is dead.

      • by brian_tanner (1022773) on Tuesday May 05 2009, @06:16PM (#27839561)

        Easy solution. Legalize non-competes, but require the company to pay the employee while bound by the non-compete.

        Sounds good, but it sets up the following far too easily:
        1) Get hired by a company that has juicy IP
        2) Sign a non-compete with "keep getting paid" clause
        3) Quit
        4) ???? (here the ??? means do whatever you want)
        4) PROFIT!

        PS: I don't support non-competes. I just always wanted an excuse to post a .... PROFIT! post on /.

        • by Abcd1234 (188840) on Tuesday May 05 2009, @06:32PM (#27839701) Homepage

          Uhuh. Or, alternatively, the company could hire lawyers who aren't complete morons, and they write up a contract which includes two termination options for the employer:

          a) Termination with non-compete, including continued pay for the duration, or
          b) Termination without non-compete

          If the company believes you possess knowledge that would be truly beneficial to their competitors, they can go with option a. For your mythical con-man, he gets option b.

      • by Lord Ender (156273) on Tuesday May 05 2009, @06:32PM (#27839697) Homepage

        Well as a tech worker, I certainly do not want to work in a state where I can be sued for switching jobs! Driving away developers certainly isn't going to help Massachusetts foster technological development.

        Your solution does seem to be the best of both worlds.

      • by jgtg32a (1173373) on Tuesday May 05 2009, @06:34PM (#27839721)
        That sounds like an intelligent solution, it'll never work.
      • That sounds great in theory.. Problem is, the non-compete still forces you to avoid any job that could in any way compete with the company you work for (which is to say, anything involving your skillset). So they can continue to pay you incredibly low wages to keep you from working for anyone else, even if you quit. This keeps you from looking for a better job, and in some cases would prevent you from getting a job after you're laid off (though you would at least get some amount of money for continuing t
    • by _avs_007 (459738) on Tuesday May 05 2009, @06:35PM (#27839737)
      My wife went through a law suit a few years ago for this... The Non-compete was eventually deemed unenforceable.

      Basically what they determined, is that the basis of a non-compete, is that the employee would be bringing something of value (which was obtained from the first employer) to a second employer, putting the first employer at a disadvantage...

      However, since my wife was laid off, it was determined that by laying her off, the first employer essentially deemed that she was no longer of any value to the company... Therefore, since her status was classified as not having any value to first employer, her employment by second employer does not place the first company at a disadvantage, because they already deemed her services as being not valuable to them.

      So basically that means, if you leave on your own accord, it may be enforceable.. But if you are fired or laid off, you cannot be held to a non-compete (In the state of Washington anyways), because by terminating your employment against your will, the company is admitting that you no longer possess anything of value to the company.
        • Re: (Score:3, Interesting)

          Look at it another way. The company choose to stop paying your wage... therefore the information or job you hold was not worth enough for THEM to keep paying for so it shouldn't stop you from getting another job with those skills. And again... they stopped PAYING you for your information so why can't you go elsewhere too.

          Courts are usually very civil on these things in terms of keeping a person working. Even in the case with IBM and Apple, Apple was able to give the guy a token job "on the couch" for 9 mon

        • by Fulcrum of Evil (560260) on Tuesday May 05 2009, @08:50PM (#27840857)

          Just because I don't have enough money to continue doing R&D, doesn't mean that my engineers don't possess valuable information that I already paid for and that is rightly my trade secret.

          Sucks to be you. You either keep them on the payroll or deal with losing them.

        • Re: (Score:3, Insightful)

          by _avs_007 (459738)
          If a company has a legitimate cause of action against a former employee transferring proprietary info, then let them make the case and be subject to a penalty if they lose. Do not confuse a non-disclosure agreement with a non-compete agreement :) That being said, if you elect to keep some engineers on staff, you are admitting that those engineers have higher value to you, than the ones you let go... When you let them go, the services they provide to another company is worth less to you than those that yo
        • by Brickwall (985910) on Tuesday May 05 2009, @10:01PM (#27841303)
          I was going to moderate on this discussion, but the hell with it.. I agree most non-competes are garbage. However, I have always signed someone else's name when requested to complete one (at least half a dozen times). No one ever checks the signature! I wonder how that would work out in court - "Hey, I didn't sign this! Someone named Frank Drakman did!".
    • Re: (Score:3, Interesting)

      Hehe, you keep on whining about socialism, we'll keep on educating the best minds in the world at the best universities in the world. Between California and Massachusetts, I think we've got the top engineering universities in MIT, Berkeley, Stanford, and Caltech, not to mention some school called Harvard in Mass which I hear is pretty good. Unless this was some sort of crazy sarcasm, but if it is it sucks.
      • Re: (Score:3, Informative)

        by Grishnakh (216268)

        How on earth do schools have anything to do with socialism? Let me clue you in: schools are where people go to learn and get degrees. Companies are where people go to work after they get out of school. In the USA, in the tech sector, these places are rarely in the same places; instead, they're usually on opposite sides of the country. There's lots of great tech schools in places like Georgia, South Carolina, North Carolina, southwest Virginia, Cleveland Ohio, upstate NY, etc. How many big-name tech com

          • Re: (Score:3, Insightful)

            by Grishnakh (216268)

            In that case, it appears socialism isn't working out too well for the east-coast states, since they're investing a lot of money into education, only to have all their graduates flee after they graduate.

            • Re: (Score:3, Funny)

              Which is why housing is so cheap in Massachusetts and California.

              It brings to mine Yogi Berra: "no one goes there anymore. It's too crowded."

    • Re: (Score:3, Funny)

      by Overzeetop (214511)

      I believe silicone valley is a bit south of where you were intending to refer. And they're not really into tech, but the IP is pretty entertaining nonetheless.

      (Sorry, that one was just too easy)