In Motorola, Inc., vs. Lemko Corp., No. 08 V 5427 (N.D. Ill. Jan. 1, 2012), a district court found that an employment agreement required employees to assign all “ideas” arising out of their employment. Motorola alleged several ex-employees breached their employment agreements by forming another company, Lemko, and filing subsequent patent applications for the company based on their work for Motorola. The employment agreement required the employees to assign to Motorola all “inventions, innovations, or ideas” related to their work at Motorola. Lemko argued the patents were not related to the work done by the employees at Motorola and moved for summary judgment. While the inventions may not have been “fully developed” while the employees were at Motorola, documents existed describing the Lemko invention and work at Motorola in similar terms. Because the employment agreement required the assignment of all ideas, the district court denied summary judgment noting that a reasonable jury could find that patent applications, even if years later, were based on “ideas” formed during their work at Motorola.