This Law Firm Publication by Jackson Lewis P.C. discusses Standard Register v. Keala, in which a Hawaii federal district court concluded that the Hawaii Supreme Court would not require an employer to provide additional consideration beyond continued at-will employment for a non-compete agreement imposed mid-employment. The court followed the majority of other jurisdictions in reaching this conclusion. The court further noted that continued at-will employment is not worthless or illusory and that inadequacy of consideration alone is not a fatal defect in an agreement. Finally, the court found that the same rule concerning adequacy of consideration should apply to both pre- and post-employment covenants. This district court opinion is not binding on the Hawaii Supreme Court.