Represented IBM in an action filed in the U.S. District Court for the Southern District of New York against Mark D. Papermaster to enforce the terms of a noncompetition agreement. Mr. Papermaster, a former IBM executive, sought to join Apple Inc. (“Apple”) as senior vice president of Devices Hardware Engineering, a position reporting to Apple CEO Steve Jobs. To protect its confidential information, IBM sought a preliminary injunction against Mr. Papermaster, and the Court granted IBM’s request, ordering Mr. Papermaster immediately to cease employment with Apple pending further order of the Court. Thereafter, the parties resolved the lawsuit on terms under which Mr. Papermaster would not begin employment with Apple until April 24, 2009, six months after leaving IBM, and would remain subject thereafter to all of his contractual and other legal duties to IBM, including the obligation not to use or disclose IBM’s confidential information. Following commencement of his employment with Apple, Mr. Papermaster was required to certify, in July 2009 and again in October 2009, that he complied with his legal obligations not to use or disclose IBM’s confidential or proprietary information. The preliminary injunction was replaced by a Consent Order under which the Court had continuing jurisdiction over the matter, including compliance enforcement powers, until October 24, 2009, one year after Mr. Papermaster’s departure from IBM.