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NT
MATTER 24-0187Northstar Mobility · Executive separation
New YorkEmploymentPrivate
Saved
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PRIVILEGED & CONFIDENTIAL · ATTORNEY WORK PRODUCT

LEGAL MEMORANDUM

To
Litigation Team
From
J. Rivera
Re
Northstar Mobility — restrictive covenant
Date
September 21, 2026

Question Presented

Whether the twenty-four-month nationwide non-compete in § 8.2 is enforceable under New York law where Northstar relies on general customer relationships rather than trade secrets or unique services.

Brief Answer

Likely not as written. New York enforces a restrictive covenant only to the extent it protects a legitimate employer interest, imposes no undue hardship, and is not injurious to the public.

Discussion

I. The covenant exceeds what is necessary to protect a legitimate interest.

A restraint aimed at ordinary competition is disfavored. Northstar must connect the restriction to trade secrets, confidential information, unique services, or protectable client relationships—not simply the loss of an employee to a competitor.

The agreement reaches every competing business in the United States for two years, regardless of the employee's role or prior customer contact. That breadth is materially disconnected from the limited interests New York recognizes.AI SUGGESTION

II. The restriction imposes substantial hardship.

Section 8.2 prevents work across an entire national industry rather than limiting solicitation of identified customers. The duration and geographic reach therefore strengthen the argument against enforcement.

[1] BDO Seidman v. Hirshberg, 93 N.Y.2d 382, 388–89 (1999).

[2] Reed, Roberts Assocs. v. Strauman, 40 N.Y.2d 303, 307–08 (1976).

[3] Brown & Brown, Inc. v. Johnson, 25 N.Y.3d 364, 370–71 (2015).

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