The changing landscape of the American legal profession brings with it an ever-evolving set of concerns for attorneys and their employers. Over the past three decades increased lawyer mobility and the growing trend towards moving legal work in-house has fueled ethical and business-related concerns. These concerns include the need for confidentiality, the protection of intellectual property and other proprietary information, the potential for economic harm to the employer and the individual attorney respectively, and the increased potential for conflicts of interest. As a result, the past decades have also seen a marked increase in the use of anticompetitive covenants and consequently litigation related to anticompetitive covenants. This article attempts to predict the final outcome of the legal status of non-compete agreements as applied to in-house counsel.