Comment Letter: Federal Trade Commission’s Proposed Non-Compete Rule

Jonathan Wolfson and Ajay Ivyer reviewed the Federal Trade Commission’s recently proposed Non-Compete Clause Rule, 88 Fed. Reg. 3482 and submitted the following comment letter. Jonathan and Ajay found the rule to be a legal overreach of the Federal Trade Commission’s power and it takes agency away from state legislators who can more carefully regulate non-compete agreements based on unique factors specific to a state labor market.