That was for Frank to keep in mind....

IMO...."70 DC Memorandum in support of motion[1]" should be tossed... As this heading is wrong.

"Statement of Issues" regarding .....the "Non Compete Agreement"

It's not a "Non Compete Agreement"

It's a Non -Disclosure Agreement  with a line item condition of non-compete for a RECIPIENT.

Once the RECIPIENT agrees to do business...They're not a RECIPIENT anymore. They do, however,  stay a RECIPIENT if they walk away from the proposed offering.

doni