Seventh Circuit rules forfeiture-for-competition clauses under Delaware law enforceable and not subject to reasonableness review

In 2021, LKQ Corporation (LKQ) filed suit against Robert Rutledge, its former plant manager, in the U.S. District Court for the Northern District of Illinois. LKQ alleged that Rutledge’s working for a competitor within nine months of his leaving LKQ breached his restricted stock unit (RSU) agreements and his separate restrictive covenant agreements. LKQ also alleged that Rutledge was unjustly enriched under the RSU agreements.