YALE PRESTON, Appellant (Plaintiff), v. MARATHON OIL COMPANY and THOMAS SMITH, Appellees (Defendants)., 2012 WY 66

Summary

After he started working for the employer, and without any additional consideration, the employee signed an agreement stating that he assigned to the employer all intellectual property he developed during his employment. He filed a patent application for an invention shortly after leaving his job. The employer sought to patent a similar invention. The district court determined that the employee was the sole inventor as to both patents and that his employee agreement was a valid contract requiring him to assign his ownership interest in the patents to the employer. The court concluded that the employee's assignment of intellectual property rights to his employer did not have to be accompanied by additional consideration, beyond the continuation of his at-will employment, to be enforceable. The agreement did not affect the employee's right to earn a living or otherwise impose an improper restraint on trade; thus, case law addressing the enforceability of agreements not to compete did not...