Non-competition agreements are prohibited in California except in connection with the sale of a business. In Alliant Insurance Services, Inc. v. Gaddy, a California court of appeal upheld a non-compete against the seller of a business which prohibited the seller from competing against the buyer in all 58 California counties, and from soliciting the seller's former clients and any clients of the buyer with which he had substantial contact during his post-sale employment with the buyer. The court dismissed the seller's attempt to characterize the restrictions as unlawful restraints of trade, because there was evidence that the buyer engaged in business in all 58 counties. Further, the non-solicitation restriction was enforceable as to the buyer's clients because the seller became an employee of the buyer and thereby developed contacts with and knowledge about those clients.