Last Tuesday, May 30, 2023, National Labor Relations Board (“NLRB”) General Counsel Jennifer Abruzzo issued Memorandum GC 23-08 (the “Memorandum”) on non-compete agreements. According to Abruzzo, non-compete agreements, in general, violate the National Labor Relations Act (“NLRA”). In addition, Abruzzo sets forth her view that the proffer, maintenance, and enforcement of employee non-compete agreements are unlawful under the NLRA.