210927 comments noncompete clauses ftc


September 29, 2021


On behalf of the U.S. Chamber of Commerce (“the Chamber”), we are pleased to submit these comments to the Federal Trade Commission (“FTC”) in response to its Solicitation for Public Comments on Contract Terms that May Harm Competition. These comments will focus on non-compete clauses, in reference to a Petition for Rulemaking to Prohibit Worker Non-Compete Clauses. That petition asks the FTC to interpret the FTC Act’s prohibition on unfair methods of competition (UMC) to “write a rule holding that the use or enforcement of non-compete clauses is a per se violation of Section 5 of the FTC Act.”