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Mitel Telecommunications Systems, Inc. v. Napolitano

Citations: 226 A.D.2d 165; 640 N.Y.S.2d 113; 1996 N.Y. App. Div. LEXIS 3661

Court: Appellate Division of the Supreme Court of the State of New York; April 9, 1996; New York; State Appellate Court

Narrative Opinion Summary

The Supreme Court of New York County, under Justice Alice Schlesinger, issued an order on June 8, 1995, denying the plaintiffs' motion for a preliminary injunction against the defendants. The plaintiffs sought to prevent the defendants from competing with their business for six months and from soliciting former customers. The court affirmed the denial, noting that the non-compete clause was limited to six months post-termination of the defendant's employment, a period which had already expired, rendering the clause unenforceable (citing Lehman v Piontkowski). Additionally, the plaintiffs failed to demonstrate any injury or favorable equities (referencing Hay Group v Nadel). The request to bar defendants from soliciting former customers was also denied, as the non-solicitation agreement was valid for three years following the sale of the business, a period that had similarly lapsed (citing MGM Ct. Reporting Serv. v Greenberg). The decision was unanimously upheld, with costs awarded.

Legal Issues Addressed

Enforceability of Non-Compete Clauses

Application: The court ruled the non-compete clause unenforceable because the specified time period had already expired.

Reasoning: The court affirmed the denial, noting that the non-compete clause was limited to six months post-termination of the defendant's employment, a period which had already expired, rendering the clause unenforceable (citing Lehman v Piontkowski).

Enforceability of Non-Solicitation Agreements

Application: The non-solicitation agreement was deemed unenforceable as the relevant time period had expired.

Reasoning: The request to bar defendants from soliciting former customers was also denied, as the non-solicitation agreement was valid for three years following the sale of the business, a period that had similarly lapsed (citing MGM Ct. Reporting Serv. v Greenberg).

Requirement for Demonstrating Injury or Favorable Equities

Application: Plaintiffs' failure to show injury or favorable equities contributed to the denial of their motion for a preliminary injunction.

Reasoning: Additionally, the plaintiffs failed to demonstrate any injury or favorable equities (referencing Hay Group v Nadel).