## Facts

- Between 1974 and 1996, Joseph Paumi worked for Intec Corporation, a Connecticut company that made specialty camera and laser inspection devices.
- Paumi held multiple roles over his tenure, starting as an engineer and later serving as the company’s general manager.
- In 1992, a Massachusetts company purchased Intec and required Intec’s managerial employees, including Paumi, to sign employment agreements containing a noncompetition provision.
- Paumi’s employment agreement included a clause stating that Massachusetts law governed the agreement.
- In 1994, the purchasing company moved to Connecticut and changed its name to Industrial Technologies, Inc.
- In 1996, Paumi resigned and soon after began working for Mayan Automation.
- Mayan Automation was described as both a supplier to, and a competitor of, Intec/Industrial Technologies.
- Industrial Technologies sued Paumi to enforce the noncompetition agreement.
- The noncompetition provision restrained Paumi for one year after termination from working for any competitor as well as any “client, customer, consultant, collaborator or supplier.”
- The noncompetition provision contained no geographic limitation.
- Industrial Technologies argued that enforcement was justified to protect goodwill and confidential knowledge relating to current and prospective customers.
- The parties disputed whether Connecticut or Massachusetts law applied and whether, and to what extent, the noncompetition provision was enforceable.

## Issues

1. Whether the Massachusetts choice-of-law clause governed the dispute in a Connecticut Superior Court action.
2. Whether a one-year noncompetition restriction that reached competitors and various business relationships, and included no geographic limit, was enforceable.
3. What relief (if any) was appropriate based on the enforceability of the restrictive covenant and the interests asserted by the employer.

## Decision

- The Connecticut Superior Court addressed the parties’ dispute over which state’s law applied to the agreement and whether the noncompetition provision was enforceable.
- The publicly available case summaries for this decision identify the dispute and the contract terms at issue but do not disclose the court’s specific disposition or the exact scope of any relief ordered.

## Legal Principles

- When an employment agreement contains a choice-of-law clause, enforceability disputes commonly turn on whether the selected state has a meaningful connection to the agreement and whether applying that law would conflict with a strong policy of the forum state.
- Noncompetition covenants are typically evaluated for reasonableness, including duration and scope, and whether the restriction is tied to legitimate employer interests such as customer relationships and confidential business information.
- A restriction that extends beyond direct competitors (for example, to customers, consultants, collaborators, or suppliers) and omits any geographic limit is often challenged as broader than necessary to protect the employer’s asserted interests.
- Claims seeking to enforce restrictive covenants often request injunctive relief aimed at preventing competitive employment and the use or disclosure of confidential information, depending on the covenant’s enforceability and the facts shown.

## Conclusion

Industrial Technologies, Inc. v. Paumi involved a longtime managerial employee who resigned and joined a company alleged to be both a supplier and competitor, leading the employer to sue in Connecticut to enforce a Massachusetts-governed, one-year noncompetition covenant with no geographic limitation and broad coverage of competitors and various business relationships; the accessible summaries confirm the disputed choice-of-law and enforceability questions but do not provide the opinion’s final disposition or the precise relief granted or denied.


Industrial Technologies, Inc. v. Paumi, 1997 Conn. Super. LEXIS 1499 (1997)