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Comprehensive Technologies International v. Software Artisans, Inc.

United States Court of Appeals for the Fourth Circuit

3 F.3d 730 (1993)

Facts

Comprehensive Technologies International (CTI) was a company that made software for personal computers. CTI’s software occupied a narrow niche in the software market. Several employees, including Dean Hawkes (defendant), left to work for a company called Software Artisans (SA) (defendant). Hawkes had signed a termination agreement that stated he would not disclose or use any confidential information and he would not compete with CTI, solicit CTI’s customers, or employ CTI’s current or former employees for one year after leaving. During Hawkes subsequent employment by SA, a competitor of CTI that developed the same types of software, he solicited CTI’s former employees. CTI sued Hawkes along with SA and several other defendants in federal district court. The noncompetition agreement restricted Hawkes from working at any competitor nationwide for an entire year. The district court found that the agreement was too restrictive and invalidated it. CTI appealed to the Fourth Circuit.

Rule of Law

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Issue

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Holding and Reasoning (Williams, J.)

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Concurrence/Dissent (Murnaghan, J.)

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