Instant Technology LLC v. DeFazio

Dist. Ct. did not err in finding after bench trial that defendants-former employees of plaintiff did not breach terms of restrictive covenants when defendants began employment with competing employment agency following their termination from plaintiff. Plaintiff failed to establish that defendants accessed plaintiff’s proprietary information about its clients after leaving their positions at plaintiff. Moreover, while defendants admitted to breaching covenant not to solicit plaintiff's staff or recruit plaintiff’s clients, Dist. Ct. could properly find that said covenants were unreasonable, where: (1) tech-staffing firms generally do not build relationships with its clients; (2) information about said clients could be found in other public forums; and (3) plaintiff could not rely on its interest in “stable workforce” to justify covenant not to recruit.