Ixchel Pharma, LLC v. Biogen, Inc

(United States Ninth Circuit) – 9th Circuit panel certified two questions to the California Supreme Court:
1) Does Section 16600 of the California Business and Professions Code apply to covenants not to compete not involving employer and employee? and
2) Does a claim for intentional interference with contractual relations require the plaintiff to plead and prove an intentionally wrongful act in cases not involving at-will employment contracts?