IANAL but I did find http://www.jacksonlewis.com/resources.php?NewsID=1465 http://www.jacksonlewis.com/resources.php?NewsID=1465 reporting that Edwards v. Arthu

IANAL but I did find http://www.jacksonlewis.com/resources.php?NewsID=1465 http://www.jacksonlewis.com/resources.php?NewsID=1465 reporting that Edwards v. Arthur Andersen LLP "holds that nonsolicitation agreements are per se unenforceable unless they relate to the sale of a business".