This Jackson Lewis LLP memorandum discusses the US Court of Appeals for the First Circuit's ruling in OfficeMax, Inc. v. Levesque. Analyzing the case under Maine law, the court held that a one year non-compete clause had expired by the time the employer tried to enforce it more than a year after its predecessor in interest acquired the company that had initially obtained the non-compete agreement. The court reversed the grant of preliminary injunction and remanded the case.