In Edwards v. Arthur Andersen LLP (2008) 44 Cal.4th 937, the Supreme Court held that in the employment context, Bus. & Prof. Code 16600 is to be strictly enforced, prohibiting enforcement of any noncompetition clause except in circumstances that are exempted by B & P Code 16601, 16602 or 16602.5.  However, this case holds that outside the employment context, and particularly during the term of a contract between the parties, the legality of a non-competition clause is to be judged by a different, more lenient standard.  Non-competition clauses may be enforceable if it does not negatively affect the public interest, is designed to protect the parties in their dealings, and does not attempt to establish a monopoly.  This standard requires an examination of the provision similar to an antitrust analysis under the rule of reason–an intensely factual inquiry.