# Employee Invention Assignment in Guam[^about] Guam has no California-style own-time carve-out and no notice requirement, but it is not a blank slate either — its 1970 Civil Code was copied from California's, so 18 GCA § 55311 makes everything an employee acquires by virtue of employment belong to the employer while 19 GCA § 31301 gives the author of any product of the mind, expressly including an invention, exclusive ownership, and no Guam decision found in our review construes either provision for inventions. Guam courts read California-derived statutes through California case law, which points to the employee owning by default, and a post-employment holdover clause that operates as a restraint faces outright voidness under 18 GCA § 88105, the verbatim twin of California's section 16600 that the Supreme Court of Guam enforced per se in Island Eye Center v. Lombard. ## Can a Guam employer require assignment of every invention? {#statutory-carve-out} **Short answer.** There is no employee-protective ceiling — Guam has no §2870-style statute voiding the assignment of a true own-time, own-resource invention — but Guam is not a bare no-statute jurisdiction either. Its 1970 Civil Code was copied from California's, and two of its provisions speak to employee-created property from opposite directions: 18 GCA § 55311 declares that everything an employee acquires by virtue of employment belongs to the employer, while 19 GCA § 31301 gives the author of any product of the mind, expressly including an invention, exclusive ownership. Neither provision has been construed for inventions in any Guam decision found in our review, so whether § 55311 operates as a partial employer-ownership rule for inventions is genuinely unsettled [^gu-55311-employer-acquisition][^gu-31301-inventor-first]. Start with what the Guam Code Annotated does and does not contain. Guam has enacted no employee-invention-assignment statute: the chapter governing service with employment (18 GCA chapter 55) contains no invention carve-out and no notice provision anywhere in its article on the obligations of employees, and the labor chapters of Title 22 contain no invention or intellectual-property provision at all. What chapter 55 does contain is a much older and much broader rule — § 55311, captioned Property Belonging to Employer — that sweeps in everything an employee acquires by virtue of the employment [^gu-55311-employer-acquisition]. "Everything which an employee acquires by virtue of his employment, except the compensation, if any, which is due to him from his employer, belongs to the latter whether acquired lawfully or unlawfully, or during or after the expiration of the term of his employment."[^gu-55311-employer-acquisition] That text is not local drafting. It was carried into Guam's 1970 Civil Code as Guam Civil Code § 1985, a verbatim copy of California Civil Code § 1985 of 1872, later recodified as California Labor Code § 2860 — the same Field Code family that produced the employer-acquisition statutes of Montana and North Dakota. And Guam has a black-letter rule for statutes with that pedigree. In *Island Eye Center, Inc. v. Lombard*, quoting its earlier decision in *Banes v. Superior Court*, the Supreme Court of Guam restated the borrowed-statute doctrine [^ie-borrowed-statute-rule]. "When Guam statutes are based on nearly identical California statutes, California case law is persuasive, absent any compelling reason to deviate from California's interpretation."[^ie-borrowed-statute-rule] Run § 55311 through that doorway and the employer-favoring reading loses much of its force. California has never used the parent statute to capture an employee invention: its employee-invention default was worked out at common law, and in *Aero Bolt & Screw Co. of California v. Iaia* a California appellate court denied an employer both title and a shop right in an employee's invention without so much as citing the employer-acquisition text — a negative inference, not a square construction, but the only California signal there is [^aero-bolt-common-law-default]. "It is well settled that the mere existence of the employer-employee relationship is not by itself sufficient to entitle the employer to partake of the benefits of the employee’s inventive genius."[^aero-bolt-common-law-default] Guam's own code also supplies a counterweight. Title 19's products-of-the-mind article — another Field Code inheritance — vests ownership of an invention in its author [^gu-31301-inventor-first]. "The author of any product of the mind, whether it is an invention, or a composition in letters or art, or a design, with or without delineation, or other graphical representation, has an exclusive ownership therein, and in the representation or expression thereof, which continues so long as the product and the representations or expressions thereof made by him remain in his possession."[^gu-31301-inventor-first] So Guam sits between the familiar camps. It is not a carve-out jurisdiction — a Guam employer can, in principle, contract for assignment more broadly than a California or Washington employer, because no statute voids the overreach. And it is not a clean no-statute jurisdiction — § 55311 hovers over the analysis as a possible employer-acquisition default that no Guam court has tested against § 31301's inventor-first text in any decision found in our review. The uncertainty comes from ambiguous, never-construed statutory text, not from any conflict in decided cases. The practical limits on an aggressive clause are ordinary contract law and, for post-employment reach, Guam's restraint-of-trade ban (see the holdover question below). ## Must a Guam employer notify the employee? {#employee-notice} **Short answer.** Not applicable. Because Guam has no invention-assignment statute, there is no statutory carve-out to notify the employee about and no notice requirement of the kind California imposes under Labor Code § 2872 or Washington imposes under RCW 49.44.140(3). The one Guam statute that touches employee acquisitions, 18 GCA § 55311, vests ownership language in the employer without conditioning anything on notice to, or disclosure by, anyone [^gu-55311-no-notice]. There is nothing to give notice of. Notice statutes exist to alert the employee to a statutory own-time carve-out that limits the assignment clause; Guam has enacted no such carve-out — chapter 55's article on the obligations of employees contains no notice or disclosure provision — so there is no statutory line for a notice to mark. That is why this entry is marked not applicable rather than a bare no: the question presupposes a statutory regime Guam does not have. Nor does the employer-acquisition statute impose any procedural formality of its own. Its text operates unconditionally, without reference to any warning, acknowledgment, or disclosure [^gu-55311-no-notice]. "Everything which an employee acquires by virtue of his employment, except the compensation, if any, which is due to him from his employer, belongs to the latter whether acquired lawfully or unlawfully, or during or after the expiration of the term of his employment."[^gu-55311-no-notice] The neighboring provision sometimes mistaken for a disclosure regime points the other way. 18 GCA § 55312 is an accounting-and-remittance rule — it obliges the *employee* to account to the employer and to give prompt notice of everything received for the employer's account; it imposes no invention-disclosure duty on either side and no employer notice obligation [^gu-55312-duty-to-account]. "An employee must, on demand, render to his employer just accounts of all his transactions in the course of his service, as often as may be reasonable, and must, without demand, give prompt notice to his employer of everything which he receives for his account."[^gu-55312-duty-to-account] As a matter of drafting hygiene, a multistate confidential-information-and-invention-assignment agreement will often carry a §2872-style notice anyway, along with a prior-inventions schedule. In Guam that is portability, not compliance — the notice neither is required nor cures anything. ## Who owns an invention by default in Guam? {#default-ownership} **Short answer.** The employee, most likely — as an openly predictive answer. Our review found no Guam decision, in any court or posture, on employee-invention ownership, the shop right, hired-to-invent, or an invention-assignment clause. The prediction rests on three converging layers: the federal baseline that rights in an invention belong to the inventor, 19 GCA § 31301's own inventor-first text expressly covering an invention, and Guam's borrowed-statute rule, under which California's construction of the identical parent statutes is persuasive — and California has never read § 55311's parent to defeat the inventor default. The unreconciled tension with § 55311's employer-acquisition text is the reason this stays a prediction rather than settled law [^stanford-inventor-default][^gu-31301-default-text][^ie-borrowed-rule-default]. Guam is an unincorporated U.S. territory whose highest local court is the Supreme Court of Guam, and federal patent law applies there of its own force — so the federal starting point is as settled in Guam as anywhere. *Stanford v. Roche* restates the premise that has governed since the first Patent Act [^stanford-inventor-default]. "Since 1790, the patent law has operated on the premise that rights in an invention belong to the inventor."[^stanford-inventor-default] Against that baseline, the traditional doctrines allocate limited rights to the employer. Under *United States v. Dubilier Condenser Corp.*, an employee hired to invent must assign the resulting patent [^dubilier-hired-to-invent], and an employee who used the employer's time, materials, and appliances owes the employer a shop right — a non-exclusive license, not ownership [^dubilier-shop-right]. "One employed to make an invention, who succeeds, during his term of service, in accomplishing that task, is bound to assign to his employer any patent obtained."[^dubilier-hired-to-invent] "where a servant, during his hours of employment, working with his master's materials and appliances, conceives and perfects an invention for which he obtains a patent, he must accord his master a non-exclusive right to practice the invention."[^dubilier-shop-right] Guam's own statutory text points the same inventor-first direction. Unlike most states, Guam has a statute that speaks to inventions by name — the Field Code products-of-the-mind provision — and it vests ownership in the author [^gu-31301-default-text]. "The author of any product of the mind, whether it is an invention, or a composition in letters or art, or a design, with or without delineation, or other graphical representation, has an exclusive ownership therein, and in the representation or expression thereof, which continues so long as the product and the representations or expressions thereof made by him remain in his possession."[^gu-31301-default-text] The complication is § 55311. Read literally, its everything-acquired-by-virtue-of-employment text would hand an in-scope invention to the employer — displacing the inventor-first baseline — and no Guam decision found in our review has reconciled the two provisions in any intellectual-property dispute [^gu-55311-default-tension]. "Everything which an employee acquires by virtue of his employment, except the compensation, if any, which is due to him from his employer, belongs to the latter whether acquired lawfully or unlawfully, or during or after the expiration of the term of his employment."[^gu-55311-default-tension] How would a Guam court break that tie? Not through a reception statute — Guam has none. 1 GCA § 700 adopts common-law rules of construction only, and its compiler comment says expressly that the section does not adopt substantive common law [^gu-1gca-700-construction-only]. "this Section does not adopt substantive common law"[^gu-1gca-700-construction-only] What Guam has instead — and it is stronger for this question — is the borrowed-statute doctrine: because §§ 55311 and 31301 are near-verbatim copies of California statutes, California case law construing the parents is persuasive [^ie-borrowed-rule-default]. "When Guam statutes are based on nearly identical California statutes, California case law is persuasive, absent any compelling reason to deviate from California's interpretation."[^ie-borrowed-rule-default] And California's construction runs the employee's way. California worked out its employee-invention default at common law, and *Aero Bolt & Screw Co. of California v. Iaia* — decided without any reference to the employer-acquisition statute from which § 55311 was copied — denied the employer both title and a shop right despite the employment relationship, synthesizing the rule that the employer takes only where the employee was hired to invent or expressly agreed to assign [^aero-bolt-mere-relationship][^aero-bolt-synthesis]. "It is well settled that the mere existence of the employer-employee relationship is not by itself sufficient to entitle the employer to partake of the benefits of the employee’s inventive genius."[^aero-bolt-mere-relationship] "A synthesis of the rules relating to such assignments would be either (a) where the employee is hired to invent (i.e. has a duty to invent) or (b) where even though there was no duty to invent, that it was part of the employment contract that if there should be an invention, that the employee would assign the title thereof to the employer."[^aero-bolt-synthesis] On the shop right itself, the most analogous appellate authority in Guam's own circuit is *Francklyn v. Guilford Packing Co.*, where the Ninth Circuit recognized a shop right that arose from the inventor inducing and assisting the use of his invention — acquiescence, not a classic employment analysis — and held the right personal and non-transferable [^francklyn-shop-right-personal]. "It is a well established principle that a shop right is personal to the employer; it cannot be assigned or transferred by contract to a third person."[^francklyn-shop-right-personal] The honest statement of Guam's default is therefore layered: the federal inventor-first baseline is binding; Guam's invention-specific statute points the same way; the borrowed California construction of the employer-acquisition text points the same way; and yet no Guam court has ever said any of this in an invention case found in our review. The drafting consequence is the one careful employers reach everywhere, only more urgent here: because the default is a prediction, a written present-assignment clause (*hereby assigns*) that transfers title automatically on conception is the dependable path, and relying on either statutory default is a litigation position, not a plan. ## Are trailing-assignment (holdover) clauses enforceable in Guam? {#holdover-clause-limit} **Short answer.** Untested locally — and the governing framework is statutory voidness, not reasonableness. No Guam decision found in our review reaches a trailing invention-assignment clause. The statute such a clause would be tested under is 18 GCA § 88105, which voids, to that extent, every contract restraining anyone from exercising a lawful profession, trade, or business outside two narrow exceptions. Section 88105 is the verbatim twin of California Business and Professions Code § 16600, the Supreme Court of Guam adopted California's per-se employee-mobility reading and voided the post-employment restraint before it in *Island Eye Center, Inc. v. Lombard*, and the Federal Circuit — applying California law under the identical statute, persuasive here but not Guam law — has voided a post-employment invention-assignment clause outright in *Whitewater West Industries, Ltd. v. Alleshouse* [^gu-88105-restraint-void][^ie-void-holding][^whitewater-void-holding]. The statutory text does the work [^gu-88105-restraint-void]. "Every contract, by which anyone is restrained from exercising a lawful profession, trade, or business of any kind, otherwise than is provided in the next two sections, is to that extent void."[^gu-88105-restraint-void] The two statutory exceptions cover the sale of a business's goodwill and partnership dissolution — neither covers an employment invention clause. And unlike the reasonableness states, Guam does not weigh duration or geography: in *Island Eye*, the first case to construe the provision, the Supreme Court of Guam traced the statute to its California parent and adopted the California framework wholesale [^ie-derived-16600]. "Our statute is derived from California Civil Code section 1673, since replaced by California Business and Professions Code section 16600. Section 16600 is virtually identical to 18 GCA § 88105."[^ie-derived-16600] The court read the section as a per-se expression of employee-mobility policy [^ie-mobility-policy] and voided the 30-month post-employment covenant before it rather than narrowing it [^ie-void-holding]. "Therefore, we hold that section 88105 evidences public policy for employee mobility and every citizen's right to pursue lawful employment or enterprise of his or her choice."[^ie-mobility-policy] "These post-employment terms are undoubtedly a restraint of trade in violation of 18 GCA § 88105 and are to that extent void."[^ie-void-holding] That is not a new posture. Decades earlier the Ninth Circuit applied the same statute in *Shelton v. Guam Service Games* and voided a Guam-wide covenant, treating the positive legislative declaration as overriding any common-law reasonableness argument [^shelton-void]. "Since this agreement attempted to make the prohibition and restraint complete within the Territory of Guam, it is to that extent void."[^shelton-void] What does that framework do to a trailing invention-assignment clause? The closest construction of the identical statutory text answers it. In *Whitewater West Industries, Ltd. v. Alleshouse*, the Federal Circuit, applying California law, held a post-employment invention-assignment provision void under § 16600 — the same section *Island Eye* treats as virtually identical to § 88105 — because it restrained the former employee's ability to work in his field [^whitewater-void-holding]. "We reverse. In particular, we reverse the judgment of breach of contract because we hold that the assignment provision is void under California law."[^whitewater-void-holding] The court reached that result even though California has an employee-protective invention statute the employer invoked as a savior — § 2870 could not rescue the clause [^whitewater-invalid-16600]. Guam has no § 2870 analogue at all, so there is not even a candidate safe harbor to argue about. "Relying on those now-undisputed premises, we conclude that the assignment provision is invalid under § 16600"[^whitewater-invalid-16600] Two hedges keep this honest. First, *Whitewater* is a Federal Circuit decision applying California law — under Guam's borrowed-statute rule it is exactly the kind of authority a Guam court would consult, but it is persuasive, not binding, and whether a trailing assignment clause is a § 88105 restraint at all has never been decided by a Guam court in our review. Second, the *Island Eye* court moves incrementally: it expressly declined to decide even the facial validity of employee non-solicitation clauses, resolving that question on overbreadth grounds instead, so it might likewise look for a narrower ground before extending § 88105 to a modest, tethered tail [^ie-declines-bright-line]. "We decline to adopt a bright-line rule when the intricacies of the issue are not before the court on appeal."[^ie-declines-bright-line] The trade-secret backdrop reinforces the prediction rather than softening it. Guam has not adopted the Uniform Trade Secrets Act [^ie-no-utsa]; *Island Eye* filled the gap by adopting the criminal code's trade-secret definition for civil misappropriation claims [^ie-ts-definition]; and the court rejected the inevitable-disclosure doctrine precisely because it would let trade-secret law operate as a de facto restraint on a former employee [^ie-inevitable-disclosure]. A court that polices even trade-secret doctrine for covert restraint effects is unlikely to smile on an untethered holdover clause — while a clause tied to the employer's actual trade secrets and confidential information looks far less like a restraint in the first place. "While the majority of jurisdictions have adopted a UTSA analogue, see supra note 8, Guam has not."[^ie-no-utsa] "Therefore, we hold that the definition of trade secrets in 9 GCA § 43.10(f) is the definition of trade secrets for civil trade-secret-misappropriation claims."[^ie-ts-definition] "For all these reasons, we reject the inevitable disclosure doctrine to establish a claim of trade-secret misappropriation."[^ie-inevitable-disclosure] > [!CAUTION] > **Drafting note.** > > Because 18 GCA § 88105 voids a covered restraint outright — to that extent void means severance, not rewriting to a reasonable scope — tether any trailing-assignment clause to inventions conceived or reduced to practice during employment, or derived from the employer's trade secrets or confidential information, and keep any post-employment tail short and narrow. The Supreme Court of Guam voided the post-employment restraint in *Island Eye* rather than narrowing it and expressly left open whether blue-penciling is even permissible, so reformation is no safe harbor: an untethered holdover that sweeps in a former employee's future inventions functions as a de facto non-compete and risks being struck entirely [^gu-88105-void-practice][^ie-void-holding-practice]. > [!NOTE] > **Practice note.** > > Do not treat either of Guam's statutory defaults as a plan. No Guam decision found in our review has ever applied 18 GCA § 55311 or 19 GCA § 31301 to an invention, and the two provisions point in opposite directions, so relying on the employer-acquisition text as a self-executing assignment is a litigation position resting on never-construed law [^gu-55311-tension-practice]. Every prediction on this page also runs through Guam's borrowed-statute rule — California case law is persuasive, not binding, and a Guam court may deviate from it for a compelling reason [^ie-borrowed-rule-practice]. Federal patent title must in any event trace back to the inventor, so use a written present-assignment (*hereby assigns*) clause that transfers title automatically on conception rather than resting on a contested statutory default or a future promise to assign [^stanford-traceback-practice]. [^about]: By Steven Obiajulu, J.D. Published by [openagreements.org](https://openagreements.org). Last reviewed 2026-07-03. License: CC BY 4.0. Steven Obiajulu, J.D. is admitted in New York, not Guam. This article synthesizes Guam primary law and is not legal advice from a Guam-admitted attorney. This article is for informational purposes only and does not create an attorney-client relationship. CC BY 4.0. Cite as Steven Obiajulu, *Employee Invention Assignment in Guam*, OpenAgreements (last updated July 3, 2026), https://openagreements.org/practice-guides/invention-assignment/us/guam. [^gu-55311-employer-acquisition]: **18 GCA § 55311** — "Everything which an employee acquires by virtue of his employment, except the compensation, if any, which is due to him from his employer, belongs to the latter whether acquired lawfully or unlawfully, or during or after the expiration of the term of his employment." *18 GCA § 55311.* [^gu-31301-inventor-first]: **19 GCA § 31301** — "The author of any product of the mind, whether it is an invention, or a composition in letters or art, or a design, with or without delineation, or other graphical representation, has an exclusive ownership therein, and in the representation or expression thereof, which continues so long as the product and the representations or expressions thereof made by him remain in his possession." *19 GCA § 31301.* [^ie-borrowed-statute-rule]: **Island Eye Ctr., Inc. v. Lombard** — "When Guam statutes are based on nearly identical California statutes, California case law is persuasive, absent any compelling reason to deviate from California's interpretation." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^aero-bolt-common-law-default]: **Aero Bolt & Screw Co. of Cal. v. Iaia** — "It is well settled that the mere existence of the employer-employee relationship is not by itself sufficient to entitle the employer to partake of the benefits of the employee’s inventive genius." *Aero Bolt & Screw Co. of Cal. v. Iaia, 180 Cal. App. 2d 728 (Cal. Ct. App. 1960).* [^gu-55311-no-notice]: **18 GCA § 55311** — "Everything which an employee acquires by virtue of his employment, except the compensation, if any, which is due to him from his employer, belongs to the latter whether acquired lawfully or unlawfully, or during or after the expiration of the term of his employment." *18 GCA § 55311.* [^gu-55312-duty-to-account]: **18 GCA § 55312** — "An employee must, on demand, render to his employer just accounts of all his transactions in the course of his service, as often as may be reasonable, and must, without demand, give prompt notice to his employer of everything which he receives for his account." *18 GCA § 55312.* [^stanford-inventor-default]: **Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Systems** — "Since 1790, the patent law has operated on the premise that rights in an invention belong to the inventor." *Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Sys., Inc., 563 U.S. 776 (2011).* [^gu-31301-default-text]: **19 GCA § 31301** — "The author of any product of the mind, whether it is an invention, or a composition in letters or art, or a design, with or without delineation, or other graphical representation, has an exclusive ownership therein, and in the representation or expression thereof, which continues so long as the product and the representations or expressions thereof made by him remain in his possession." *19 GCA § 31301.* [^ie-borrowed-rule-default]: **Island Eye Ctr., Inc. v. Lombard** — "When Guam statutes are based on nearly identical California statutes, California case law is persuasive, absent any compelling reason to deviate from California's interpretation." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^dubilier-hired-to-invent]: **United States v. Dubilier Condenser Corp.** — "One employed to make an invention, who succeeds, during his term of service, in accomplishing that task, is bound to assign to his employer any patent obtained." *United States v. Dubilier Condenser Corp., 289 U.S. 178 (1933).* [^dubilier-shop-right]: **United States v. Dubilier Condenser Corp.** — "where a servant, during his hours of employment, working with his master's materials and appliances, conceives and perfects an invention for which he obtains a patent, he must accord his master a non-exclusive right to practice the invention." *United States v. Dubilier Condenser Corp., 289 U.S. 178 (1933).* [^gu-55311-default-tension]: **18 GCA § 55311** — "Everything which an employee acquires by virtue of his employment, except the compensation, if any, which is due to him from his employer, belongs to the latter whether acquired lawfully or unlawfully, or during or after the expiration of the term of his employment." *18 GCA § 55311.* [^gu-1gca-700-construction-only]: **1 GCA § 700** — "this Section does not adopt substantive common law" *1 GCA § 700.* [^aero-bolt-mere-relationship]: **Aero Bolt & Screw Co. of Cal. v. Iaia** — "It is well settled that the mere existence of the employer-employee relationship is not by itself sufficient to entitle the employer to partake of the benefits of the employee’s inventive genius." *Aero Bolt & Screw Co. of Cal. v. Iaia, 180 Cal. App. 2d 728 (Cal. Ct. App. 1960).* [^aero-bolt-synthesis]: **Aero Bolt & Screw Co. of Cal. v. Iaia** — "A synthesis of the rules relating to such assignments would be either (a) where the employee is hired to invent (i.e. has a duty to invent) or (b) where even though there was no duty to invent, that it was part of the employment contract that if there should be an invention, that the employee would assign the title thereof to the employer." *Aero Bolt & Screw Co. of Cal. v. Iaia, 180 Cal. App. 2d 728 (Cal. Ct. App. 1960).* [^francklyn-shop-right-personal]: **Francklyn v. Guilford Packing Co.** — "It is a well established principle that a shop right is personal to the employer; it cannot be assigned or transferred by contract to a third person." *Francklyn v. Guilford Packing Co., 695 F.2d 1158 (9th Cir. 1983).* [^gu-88105-restraint-void]: **18 GCA § 88105** — "Every contract, by which anyone is restrained from exercising a lawful profession, trade, or business of any kind, otherwise than is provided in the next two sections, is to that extent void." *18 GCA § 88105.* [^ie-void-holding]: **Island Eye Ctr., Inc. v. Lombard** — "These post-employment terms are undoubtedly a restraint of trade in violation of 18 GCA § 88105 and are to that extent void." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^whitewater-void-holding]: **Whitewater West Industries, Ltd. v. Alleshouse** — "We reverse. In particular, we reverse the judgment of breach of contract because we hold that the assignment provision is void under California law." *Whitewater West Indus., Ltd. v. Alleshouse, 981 F.3d 1045 (Fed. Cir. 2020).* [^ie-derived-16600]: **Island Eye Ctr., Inc. v. Lombard** — "Our statute is derived from California Civil Code section 1673, since replaced by California Business and Professions Code section 16600. Section 16600 is virtually identical to 18 GCA § 88105." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^ie-mobility-policy]: **Island Eye Ctr., Inc. v. Lombard** — "Therefore, we hold that section 88105 evidences public policy for employee mobility and every citizen's right to pursue lawful employment or enterprise of his or her choice." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^shelton-void]: **Shelton v. Guam Service Games** — "Since this agreement attempted to make the prohibition and restraint complete within the Territory of Guam, it is to that extent void." *Shelton v. Guam Service Games, 239 F.2d 902 (9th Cir. 1956).* [^whitewater-invalid-16600]: **Whitewater West Industries, Ltd. v. Alleshouse** — "Relying on those now-undisputed premises, we conclude that the assignment provision is invalid under § 16600" *Whitewater West Indus., Ltd. v. Alleshouse, 981 F.3d 1045 (Fed. Cir. 2020).* [^ie-declines-bright-line]: **Island Eye Ctr., Inc. v. Lombard** — "We decline to adopt a bright-line rule when the intricacies of the issue are not before the court on appeal." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^ie-no-utsa]: **Island Eye Ctr., Inc. v. Lombard** — "While the majority of jurisdictions have adopted a UTSA analogue, see supra note 8, Guam has not." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^ie-ts-definition]: **Island Eye Ctr., Inc. v. Lombard** — "Therefore, we hold that the definition of trade secrets in 9 GCA § 43.10(f) is the definition of trade secrets for civil trade-secret-misappropriation claims." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^ie-inevitable-disclosure]: **Island Eye Ctr., Inc. v. Lombard** — "For all these reasons, we reject the inevitable disclosure doctrine to establish a claim of trade-secret misappropriation." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^gu-88105-void-practice]: **18 GCA § 88105** — "Every contract, by which anyone is restrained from exercising a lawful profession, trade, or business of any kind, otherwise than is provided in the next two sections, is to that extent void." *18 GCA § 88105.* [^ie-void-holding-practice]: **Island Eye Ctr., Inc. v. Lombard** — "These post-employment terms are undoubtedly a restraint of trade in violation of 18 GCA § 88105 and are to that extent void." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^gu-55311-tension-practice]: **18 GCA § 55311** — "Everything which an employee acquires by virtue of his employment, except the compensation, if any, which is due to him from his employer, belongs to the latter whether acquired lawfully or unlawfully, or during or after the expiration of the term of his employment." *18 GCA § 55311.* [^ie-borrowed-rule-practice]: **Island Eye Ctr., Inc. v. Lombard** — "When Guam statutes are based on nearly identical California statutes, California case law is persuasive, absent any compelling reason to deviate from California's interpretation." *Island Eye Ctr., Inc. v. Lombard, 2020 Guam 32.* [^stanford-traceback-practice]: **Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Systems** — "Thus, although others may acquire an interest in an invention, any such interest — as a general rule — must trace back to the inventor." *Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Sys., Inc., 563 U.S. 776 (2011).*