On August 24th, the Second Circuit certified to the New York Court of Appeals a question concerning the "Mohawk Doctrine," a line of New York cases which prohibit, in perpetuity, a voluntary seller of a client's good will from improperly soliciting business from that client after the client's business, including its good will, is transferred to the purchaser. In the instant case defendant, principal in an investment management firm, sold his firm and its good will to another investment manager. The Second Circuit asked whether defendant violated the Mohawk Doctrine by participating in the development of a plan, in response to a former client's inquiries, in which others at defendant's new firm would solicit the client and defendant to passively participate in a solicitation meeting. Bessemer Trust Co., NA v. Branin.