Industrial Technologies, Inc. v. Paumi

Between 1974 and 1996, Joseph Paumi (defendant) worked for a Connecticut company called Intec Corporation, which made specialty camera and laser inspection devices. Paumi held numerous positions, starting as an engineer and ending as the general manager. In 1992, a Massachusetts company purchased Intec, and the purchaser required all managerial employees of Intec, including Paumi, to sign employment agreements that contained a noncompetition provision. Paumi’s employment agreement provided that the agreement was governed by Massachusetts law. In 1994, the purchaser moved to Connecticut and changed its name to Industrial Technologies, Inc. (plaintiff). In 1996, Paumi resigned from Intec, and soon thereafter he went to work for Mayan Automation, a supplier to and competitor of Intec. Industrial Technologies sued Paumi to enforce the noncompetition agreement, which restrained Paumi from working for any competitor, “client, customer, consultant, collaborator or supplier”; contained no geographic limitation; and lasted for one year after termination. The parties disputed whether Connecticut or Massachusetts law applied and whether and to what extent the noncompetition agreement was enforceable. Industrial Technologies maintained that the noncompetition agreement should be enforced to protect Intec’s goodwill and confidential knowledge regarding current and prospective customers.