Law360, New York (July 30, 2015, 11:05 AM EDT) -- On July 14, 2015, the Seventh Circuit issued its opinion in Instant Technology LLC v. DeFazio.[1] Part of this appeal centered on the district court's ruling that certain post-employment restrictive covenants were unenforceable because in Fifield v. Premier Dealer Services Inc., the Illinois Appellate Court for the First District held that in the absence of evidence of other compensation, a restrictive covenant lacks adequate consideration unless the employee has been employed for two years or more — the Fifield rule.[2] This was the first opportunity for the Seventh Circuit to consider an issue which has baffled litigants and divided the district court. But, the Seventh Circuit did not discuss the Fifield rule in its opinion, leaving the subject open to continued debate and uncertainty....