The Western District of New York recently denied summary judgment to defendants Jarrett and Kurtz, former employees of plaintiff Renaissance. Renaissance, a company working within the dairy industry to provide vitamin and mineral supplements for cows, alleged that the defendants conspired to resign simultaneously to form a competitive company, “Cows Come First,” and to take several former Renaissance employees with them. Renaissance asserted that this was in violation of a “non-recruitment” or “anti-raiding” clause incorporated into the defendants’ contracts. The clause essentially prohibited any attempts to “solicit, divert or take away” employees of Renaissance to competitive ventures for 5 years after leaving. The court denied the defendants’ motion, stating that the plaintiff had a legitimate interest in protecting client relationships developed at its expense, and that it had provided enough supporting facts regarding the alleged breach to survive summary judgment. The court also noted that other defensive arguments, such as geographic and temporal overbreadth and coercion, were accompanied by insufficient preliminary evidence and would be best left to a trier of fact.