Innovation Ventures LLC v. Liquid Manufacturing LLC

Summary

The court held that the parties’ Equipment Manufacturing and Installation Agreement and Nondisclosure Agreement were supported by consideration because the agreements contemplated termination on 14 days’ notice and the plaintiff exercised that contractual right. It further held that commercial noncompete agreements must be evaluated under the rule of reason, rather than the statutory framework governing employee noncompetes. The court affirmed summary disposition on claims lacking a genuine factual dispute, but remanded claims involving possible breaches of the Nondisclosure Agreement and production of products other than Eternal Energy.