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This article indicates moving to California can work, although it's not really clear legally why: http://www.boston.com/business/articles/2007/12/30/why_nonco...

To me this article strongly implies non-competes are non-enforcable after moving: http://www.crn.com/it-channel/18815740;jsessionid=50NGMBUQKT...

EMC is such a junk yard dog in this area and the allegations are described with sufficient specificity that it sounds like whatever non-completes Karwowska signed outside of California they couldn't be used against her when she presumably moved to Silicon Valley. EMC could only claim nondisclosure and nonsolicitation agreement violations....




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