In Deloitte & Touche USA LLP v. Lamela, 2007 WL 1114075 (Del. Ch., April 6,2007), read opinion here, the Chancery Court applied Florida’s substantive law to address whether a 2-year covenant not to compete should be extended to cover the full 2 years, in light of the competition that allegedly occurred after the employment terminated. The Florida statute bases enforcement on legitimate business interests instead of a "contract enforcement" approach.  This opinion addressed cross motions for summary judgment, and the court required further factual development. Two prior decisions have been issued by the court in this case, one of them granting a a partial injunction based on the Delaware procedural rules for such relief. See summaries  here and here on my blog.