To enforce the non-compete clause a media outlet would have to show that they suffer more by an individual working elsewhere than that individual would do by not working (Above). They would have to to show a court that they were suffering significantly by the individual's alternate work, and more importantly, the company would have to show that the hardship placed on an individual by the non-compete (IE not working for alternate media for year+) was not undue. Basically, enforcing non-compete clauses against young journalists is not easy.
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