The challenge is that California is well outside the mainstream on this. In most other states noncompetes are taken for granted. Nation-wide businesses struggle to come up with noncompete terms that will hold up in California as well as the rest of the country.

The Anderson case was in the latter category- a so called “narrow restraint” that Anderson hoped it could slip past the California courts. No such luck.

California *does* allow employers to prevent former employees using the employer's confidential information in the service of a new company. That is likely what the Tokuda/Shen case was about.

And last, please see (and support) Bijan Sabet's (bijansabet.com) campaign to get Massachusetts and other states to follow the California rule. As long as we don't steal company secrets we should be able to work for whomever we want.