An interesting decision on non-compete agreements.  The Court of Appeals in Houston found a non-compete reasonable. See:  Gallagher Healthcare Ins Services v. Volgesang.  The former employee was an insurance broker for Gallagher Healthcare.  After twelve years, she resigned to work for a competitor.  The non-compete provided that the employee could not have contact with 80 customers she had done business with in the prior two years for another two years working for the competitor.  The court found this provision a reasonable substitute for the customary geographical limitation.  So, instead of the typical geographical limit, this non-compete provided the employee could not contact for two years her prior customers.  See more at Russ Cawyer’s post about this case.