In our June 30, 2008 Mass Media Update, we noted that the FCC's Media Bureau had issued a decision that purports to ban the use of programming-based non-compete contracts. More recently, New York passed a law that bans employee non-compete contracts and the California Supreme Court struck down several lower court decisions that had chipped away at the state's strict ban on employee non-compete contracts. In addition to California and New York, six other states ban some form of non-compete contracts: including Arizona, Connecticut, Illinois, Maine, Massachusetts and Washington.