RLM Communications, Inc. v. Tuschen

Amy Tuschen (defendant) signed a noncompete agreement with RLM Communications (RLM) (plaintiff), a cyber-security contractor, barring her for one year from participating -- directly or indirectly -- in any business similar to whatever RLM did at the time or might do in the future. After six years at RLM, Tuschen left for a smaller direct competitor, eScience, and helped it compete against RLM for a government contract; before leaving, she had also copied files from her RLM laptop onto a CD. RLM sued for breach of the noncompete and confidentiality agreements and misappropriation of trade secrets, but the district court granted summary judgment to the defendants on all claims.