Illinois Appellate Court upholds enforcement of noncompete against salesman; discusses standards for enforcement in sales context

Hanchett Paper Co. v. Melchiorre (June 27, 2003)

Key is “near-permanent” customer relationships.

“To determine whether an employer has a near-permanent relationship with its customers, Illinois courts consider the following factors:

‘(1) the length of time required to develop the clientele; (2) the amount of money invested to acquire clients; (3) the degree of difficulty in acquiring clients; (4) the extent of personal customer contact by the employee; (5) the extent of the employer’s knowledge of its clients; (6) the duration of the customer’s association with the employer; and (7) the continuity of the employer-customer relationships.’”

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