In Wisconsin, post-employment restrictive covenants must be “reasonable” to be enforced. In Manitowoc Company, Inc. v. Lanning, the Wisconsin Supreme Court recently stated that post-employment non-solicitation agreements must meet the same standard as other post-employment restrictive covenants (e.g., non-competition and non-disclosure agreements). Specifically, a “reasonable” non-solicitation agreement must be necessary for the protection of the employer, provide reasonable time and territorial limits, and not be oppressive to the employee or contrary to public policy.