The following excerpt is from Campbell v. Board of Trustees of Leland Stanford Junior University, 817 F.2d 499 (9th Cir. 1987):
The district court below cited Monogram Industries v. Sar Industries, 64 Cal.App.3d 692, 698, 134 Cal.Rptr. 714, 718-19 (1976), for the proposition that the California courts imply a reasonableness standard into sections 16600 to 16602 except in the employer-employee context. The court found also that the covenant not to compete in this case is "inherently reasonable."
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