Authors' note on the noncompete agreement.

• Author: Wilson, Courtney B.
• Position: Letters - Letter to the Editor

Subsequent to publication of "Outrunning Contractual Noncompete Undertakings ..." in the December Bar Journal, the 11th Circuit let stand a declaratory judgment approving an employee's deliberate strategy of moving from Florida to Georgia, misleading his employer, and racing to the courthouse to take advantage of the federal "first-filed" rule and void his noncompete agreement ("NCA") under Georgia law. Manuel v. Convergys Corp., 2005 U.S. App. LEXIS 24549 (11th Cir. November 15, 2005).

Because the former employer sought to enforce an NCA against an employee living and working in...