It turns out that much depends on the exact matrix of facts in court. The very concept of adequacy, which is essential to the doctrine of trade restriction, necessarily requires a precise analysis of the relevant facts. A contractual obligation to be non-negotiable is null and void and unen applicable to the promisor, as it is contrary to public policy of trade promotion, unless the restriction of trade is appropriate to protect the interests of the buyer of a business.  Trade restrictions may also appear in restrictive agreements in employment contracts after termination. Lowe v. Peers set a precedent in the Marriage Limitation Act. In this case, the defendant argued that if he married someone other than the plaintiff, he would give her £1,000 within three months of her marriage. Such an agreement is inconclusive. The 1911 Supreme Court decision in Standard Oil Company of New Jersey v. The United States  relies on Taft`s analysis of the rule of reason. In this case, the court found that a treaty violated the Sherman Act only if the treaty «inappropriately» restricts trade, that is, if the treaty has monopoly consequences.
According to the Court of Justice, a wider importance would prohibit normal and customary treaties, thus violating freedom of contract. The Court therefore upheld the rule of reason in Addyston Pipe, which in turn stems from Mitchel/Reynolds and the Common Law of Restraints of Trade. One of the principles is that a gentleman does not have the right to prevent his employee from offering competition after the termination of his employment relationship, but that he is entitled to adequate protection against the exploitation of trade secrets. In Mason v. Provident Clothing Co, the House of Lords did not allow an employer to restrict its advertiser for a period of three years after leaving service. Viscount HALDANE LC indicated that the ability to advertise is a natural gift and is not due to specific training from the employer. If they had merely asked him not to attach himself to paintings in the field in which he had actually contributed to the construction of the goodwill of their enterprise or in a field limited to places where the knowledge he had acquired in his employment could clearly have been used to their detriment, they would have obtained the right to detain him within those borders. On the other hand, to Fitch v. Dewes, the House of Lords allowed an alliance by which a lawyer was recycled by practice within 7 miles of the city, which was reasonably necessary to protect the interests of both parties. But under no circumstances would the court allow covenants against competitions.