On March 22, 2023, the Firm submitted a comment letter to the Federal Trade Commission (the “Commission”) in response to the Commission’s January 2023 Notice of Proposed Rulemaking regarding non-compete clauses. Our comment letter is publicly available here: https://www.regulations.gov/comment/FTC-2023-0007-10493.
Our comment letter focuses on certain background dynamics relating to the Commission’s reasoning for the final non-compete clause rule. We also provide certain recommendations regarding the final non-compete clause rule that, if implemented by the Commission, would, in our view, increase the effectiveness of the final non-compete clause rule in advancing competition in the marketplace while also protecting the interests of employers and workers under pro-market circumstances.
We are available to discuss our Firm’s perspective in the comment letter upon request. Our full letter can also be found below.
Moulton Moore Stella LLP Comment Letter on Commission’s Non-Compete Clause NPRM (Final)