Reed, Roberts Associates, Inc. v. Strauman
Court of Appeals of New York
40 N.Y. 2d 202 (1976)
John Strauman (defendant) signed a restrictive covenant permanently barring him from soliciting Reed, Roberts Associates' (plaintiff) clients upon termination, then rose over eleven years to senior vice president before leaving to start his own competing company; Reed Roberts sued to enforce the covenant, but the potential customers for its business were readily identifiable through national industry publications rather than through any proprietary customer list Strauman had taken. The trial court permanently enjoined Strauman from soliciting Reed Roberts's customers, the appellate division affirmed, and Strauman appealed.
Whether a non-solicitation clause in a restrictive covenant between an employer and employee is enforceable if the employer's customer names are easily obtainable through public sources.