Often times when an employee leaves for employment at a competing business and is under a non-compete, the question arises who other than the employee should receive the threat letter to cease and desist violation of the non-compete? Often times, the former employer will consider sending a threat letter to the new employer. At other times if the non-compete language is suggestive of such, customers in the industry might also receive a threat letter. Recently, there was a case decided in the Eastern District of Michigan, Bonds v Philips Electronic North America, where the former employee sued his former employer for sending a letter to his new employer causing his termination. The Court ultimately decided in favor of the former employer, but the analysis leaves the door open for a former employee to sue his former employer in the event that the non-compete threat letter crosses the line.