In GoHealth, LLC v. Zoom Health, Inc., 2013 WL 6183024, the Northern District provides a detailed summary of the necessary Illinois pleading elements of some signature business torts in a diversity contract dispute involving the sale of insurance products. Plaintiff and defendants entered into a written agreement where plaintiff would sell insurance product leads to defendants for …
Category Archives: Trade Secrets
Facebook Announcement Doesn’t Equal Improper Client Solicitation: Mass. Court
In Invidia v. DiFonzo, 30 Mass. L.Rptr 390 (2012), a hair salon sued a former stylist for breaching a non-compete and non-solicitation clause in her employment agreement. The Court examined whether the new employer’s posting a job change on defendant’s Facebook page and “friending” former clients was improper solicitation. The employment contract contained a non-compete spanning two years and …
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Successor Corporation Can’t Enforce Expired Restrictive Covenants
Stericycle, Inc. v. Carney, 2013 WL 3671288 (N.D.Ill. 2013) is post-worthy for its useful gloss on the enforceability of restrictive covenants, Federal pleading requirements and a purchasing corporation’s standing to assert the restrictive covenant rights of its predecessor. Facts: In 2007 and 2008, defendant signed employment agreements (the “SEI Agreements”) with SEI, his former employer. …
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