{
  "type": "practice-guide",
  "canonical": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma",
  "links": [
    {
      "rel": "self",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma.json",
      "type": "application/json"
    },
    {
      "rel": "alternate",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma",
      "type": "text/html"
    },
    {
      "rel": "alternate",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma/markdown",
      "type": "text/markdown"
    },
    {
      "rel": "alternate",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma/json",
      "type": "application/json"
    }
  ],
  "data": {
    "topic": "invention-assignment",
    "state": "oklahoma",
    "frontmatter": {
      "title": "Employee Invention Assignment in Oklahoma",
      "description": "Oklahoma has no employee-invention-assignment statute in either direction — no California-style own-time carve-out or notice duty, and no employer-acquisition default. Under Amoco Production Co. v. Lindley an employee's invention remains the employee's absent an express or implied agreement, and an undefined contractual invention captures only patentable subject matter; the hired-to-invent exception operates as Oklahoma implied-in-fact contract law under Skycam, LLC v. Bennett, and a post-employment holdover clause that functions as a restraint faces outright voidness under 15 O.S. § 217 rather than reasonableness balancing.",
      "state": "Oklahoma",
      "lastReviewed": "2026-07-03",
      "license": "CC BY 4.0",
      "authors": [
        "steven-obiajulu"
      ],
      "summary": {
        "bottomLine": "Oklahoma has no employee-invention-assignment statute in either direction — no §2870-style own-time carve-out and no employer-acquisition default; under Amoco Production Co. v. Lindley the employee's invention remains the employee's property absent an express or implied agreement, and an undefined contractual invention captures only patentable subject matter, with the hired-to-invent exception applied as Oklahoma implied-in-fact contract law in Skycam, LLC v. Bennett. A post-employment holdover clause that operates as a restraint faces the void-to-that-extent rule of 15 O.S. § 217 outside narrow statutory safe harbors, § 219A(B) voids conflicting employment-contract provisions, and Oklahoma courts refuse to sever the offending words rather than voiding the clause.",
        "keyLaw": "Okla. Stat. tit. 15, §§ 217, 219A; Amoco Production Co. v. Lindley, 1980 OK 6, 609 P.2d 733; Skycam, LLC v. Bennett, 900 F. Supp. 2d 1264 (N.D. Okla. 2012)",
        "statutoryCarveOut": "none",
        "defaultOwnership": "employee",
        "employeeNoticeRequired": "n/a",
        "holdoverClauseLimit": "statutoryLimit",
        "carveOutScope": "Oklahoma has no statutory own-time carve-out and no employer-acquisition statute; the reach of an assignment clause is bounded by ordinary contract law and the Amoco construction rule that an undefined contractual invention captures only patentable subject matter, and post-employment reach is limited by the void-outright restraint rule of 15 O.S. § 217 rather than a reasonableness test."
      },
      "about": [
        "Oklahoma invention assignment",
        "Oklahoma employee invention ownership",
        "Amoco Production Co. v. Lindley",
        "Skycam LLC v. Bennett hired to invent",
        "15 O.S. Section 217 restraint of trade",
        "Oklahoma holdover trailing assignment",
        "Oklahoma Invention Development Services Act"
      ],
      "translations": [
        {
          "language": "中文",
          "status": "planned"
        },
        {
          "language": "Español",
          "status": "planned"
        },
        {
          "language": "Português",
          "status": "planned"
        },
        {
          "language": "Deutsch",
          "status": "planned"
        }
      ],
      "relatedForm": {
        "slug": "openagreements-confidentiality-invention-assignment-agreement"
      }
    },
    "questions": [
      {
        "slug": "statutory-carve-out",
        "label": "Can the employer require assignment of every invention?",
        "heading": "Can an Oklahoma employer require assignment of every invention?",
        "answerText": "There is no statutory ceiling — and no statute pointing the other way either. Oklahoma has no employee-invention-assignment statute of any kind: no §2870-style carve-out protecting an employee's own-time, own-resource inventions, and no employer-acquisition default vesting work product in the employer. The reach of an assignment clause is a matter of ordinary contract law, and the Oklahoma Supreme Court construes that reach narrowly — under Amoco Production Co. v. Lindley, an undefined contractual invention captures only patentable subject matter.",
        "sources": [
          {
            "id": "amoco-invention-patentable",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Amoco Production Co. v. Lindley",
            "citation": "Amoco Production Co. v. Lindley, 1980 OK 6, 609 P.2d 733.",
            "url": "https://www.courtlistener.com/opinion/1430322/amoco-production-co-v-lindley/",
            "deepLink": "https://www.courtlistener.com/opinion/1430322/amoco-production-co-v-lindley/#:~:text=Both%20definitions%20are%20based%20on,whether%20it%20is%20or%20not.",
            "proposition": "Amoco Production Co. v. Lindley holds that where an employment contract does not define the term, an invention must be patentable — whether or not actually patented — to be classified as an invention for purposes of determining ownership under the contract, a construction rule that bounds the reach of an undefined assignment clause.",
            "verbatimQuote": "Both definitions are based on patent law; thus it follows that “invention”, to be so classified for purposes of determining ownership under the contract, must be patentable whether it is or not.",
            "date": "1980-01-15",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-amoco-invention-patentable"
          },
          {
            "id": "amoco-software-outside-contract",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Amoco Production Co. v. Lindley",
            "citation": "Amoco Production Co. v. Lindley, 1980 OK 6, 609 P.2d 733.",
            "url": "https://www.courtlistener.com/opinion/1430322/amoco-production-co-v-lindley/",
            "deepLink": "https://www.courtlistener.com/opinion/1430322/amoco-production-co-v-lindley/#:~:text=The%20software%20system%20is%20not,it%20for%20his%20own%20benefit.",
            "proposition": "Amoco Production Co. v. Lindley held that the employee's software system — unpatentable under the patent law of the day — was not an invention within the undefined assignment clause, so on the contract alone the employee could disclose it or use it for his own benefit.",
            "verbatimQuote": "The software system is not an invention, so on the sole basis of the contract Mr. Lindley could disclose it, or use it for his own benefit.",
            "date": "1980-01-15",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-amoco-software-outside-contract"
          }
        ]
      },
      {
        "slug": "employee-notice",
        "label": "Must the employer give the employee written notice of the carve-out?",
        "heading": "Must an Oklahoma employer notify the employee?",
        "answerText": "Not applicable. Oklahoma has no invention-assignment statute, so there is no statutory carve-out to notify the employee about and no notice duty of the kind California imposes under Labor Code § 2872 or Washington imposes under RCW 49.44.140(3). What Oklahoma enforces instead is contractual: the employer's rights in an employee's invention, if any, spring from the employment agreement itself, so any disclosure or assignment duty arises from the contract rather than from a notice-backed statute.",
        "sources": [
          {
            "id": "amoco-contract-duty",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Amoco Production Co. v. Lindley",
            "citation": "Amoco Production Co. v. Lindley, 1980 OK 6, 609 P.2d 733.",
            "url": "https://www.courtlistener.com/opinion/1430322/amoco-production-co-v-lindley/",
            "deepLink": "https://www.courtlistener.com/opinion/1430322/amoco-production-co-v-lindley/#:~:text=were%20it%20otherwise%20but%20for,the%20property%20of%20the%20employee.",
            "proposition": "Amoco Production Co. v. Lindley, approving the trial court's statement of the rule, supports the rule that the employer's rights in an employee's invention spring from the employment agreement — absent an express or implied agreement the invention remains the employee's property — so in Oklahoma any disclosure or assignment duty arises from the contract, not from a notice-requiring statute.",
            "verbatimQuote": "were it otherwise but for an express agreement or implied agreement in the employment relationship, then the employee’s invention remains the property of the employee.",
            "date": "1980-01-15",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-amoco-contract-duty"
          }
        ]
      },
      {
        "slug": "default-ownership",
        "label": "Absent a written assignment, who owns the invention?",
        "heading": "Who owns an invention by default in Oklahoma?",
        "answerText": "The employee, unless an express or implied agreement gives it to the employer. Oklahoma has direct authority on the point: in Amoco Production Co. v. Lindley the Oklahoma Supreme Court approved the rule that absent an express or implied agreement in the employment relationship, the employee's invention remains the employee's property. The main exception — the employee hired to invent — operates in Oklahoma as implied-in-fact contract law: a federal court applying Oklahoma law in Skycam, LLC v. Bennett ran the hired-to-invent framework through Oklahoma's implied-contract statutes and held the employer takes only what the employee was actually employed to invent.",
        "sources": [
          {
            "id": "amoco-employee-default",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Amoco Production Co. v. Lindley",
            "citation": "Amoco Production Co. v. Lindley, 1980 OK 6, 609 P.2d 733.",
            "url": "https://www.courtlistener.com/opinion/1430322/amoco-production-co-v-lindley/",
            "deepLink": "https://www.courtlistener.com/opinion/1430322/amoco-production-co-v-lindley/#:~:text=were%20it%20otherwise%20but%20for,the%20property%20of%20the%20employee.",
            "proposition": "Amoco Production Co. v. Lindley, approving the trial court's statement of the rule, supports Oklahoma's default that absent an express or implied agreement in the employment relationship, the employee's invention remains the property of the employee.",
            "verbatimQuote": "were it otherwise but for an express agreement or implied agreement in the employment relationship, then the employee’s invention remains the property of the employee.",
            "date": "1980-01-15",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-amoco-employee-default"
          },
          {
            "id": "stanford-inventor-baseline",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Systems",
            "citation": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Sys., Inc., 563 U.S. 776 (2011).",
            "url": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/",
            "deepLink": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/#:~:text=Since%201790%2C%20the%20patent%20law,invention%20belong%20to%20the%20inventor.",
            "proposition": "Stanford v. Roche confirms the long-standing premise of U.S. patent law that rights in an invention belong to the inventor — the federal baseline Oklahoma's employee-owns default matches, and the reason a written present assignment is still needed for clean legal title.",
            "verbatimQuote": "Since 1790, the patent law has operated on the premise that rights in an invention belong to the inventor.",
            "date": "2011-06-06",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-stanford-inventor-baseline"
          },
          {
            "id": "dubilier-hired-to-invent",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "United States v. Dubilier Condenser Corp.",
            "citation": "United States v. Dubilier Condenser Corp., 289 U.S. 178 (1933).",
            "url": "https://www.courtlistener.com/opinion/1087847/united-states-v-dubilier-condenser-corp/",
            "deepLink": "https://www.courtlistener.com/opinion/1087847/united-states-v-dubilier-condenser-corp/#:~:text=One%20employed%20to%20make%20an,his%20employer%20any%20patent%20obtained.",
            "proposition": "United States v. Dubilier Condenser Corp. supplies the framework the Oklahoma cases draw on — an employee hired to make an invention must assign the resulting patent, while an employee not hired to invent ordinarily keeps the invention subject at most to the employer's shop right.",
            "verbatimQuote": "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.",
            "date": "1933-05-08",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-dubilier-hired-to-invent"
          },
          {
            "id": "skycam-two-exceptions",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Skycam, LLC v. Bennett",
            "citation": "Skycam, LLC v. Bennett, 900 F. Supp. 2d 1264 (N.D. Okla. 2012).",
            "url": "https://www.courtlistener.com/opinion/8719889/skycam-llc-v-bennett/",
            "deepLink": "https://www.courtlistener.com/opinion/8719889/skycam-llc-v-bennett/#:~:text=Courts%20recognize%20two%20exceptions%20to,may%20belong%20to%20the%20employer.%E2%80%9D",
            "proposition": "Skycam, LLC v. Bennett, applying Oklahoma law, states the two exceptions to the inventor-owns default — an express contract, and the hired-to-invent doctrine — quoting the Federal Circuit's formulation in Banks v. Unisys Corp., 228 F.3d 1357, 1359 (Fed. Cir. 2000).",
            "verbatimQuote": "Courts recognize two exceptions to this rule: first, where the employee is a party to an express contract giving the employer the patent rights and second, “where an employee is hired to invent something or solve a particular problem, the property of the invention related to this effort may belong to the employer.”",
            "date": "2012-09-30",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-skycam-two-exceptions"
          },
          {
            "id": "skycam-implied-contract",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Skycam, LLC v. Bennett",
            "citation": "Skycam, LLC v. Bennett, 900 F. Supp. 2d 1264 (N.D. Okla. 2012).",
            "url": "https://www.courtlistener.com/opinion/8719889/skycam-llc-v-bennett/",
            "deepLink": "https://www.courtlistener.com/opinion/8719889/skycam-llc-v-bennett/#:~:text=Oklahoma%20law%20recognizes%20implied%20contracts.%2015%20O.S.%20%C2%A7%20131.",
            "proposition": "Skycam, LLC v. Bennett grounds the hired-to-invent doctrine in Oklahoma's implied-contract statute — the court applied the exception as Oklahoma implied-in-fact contract law under 15 O.S. § 131 rather than as free-standing federal common law.",
            "verbatimQuote": "Oklahoma law recognizes implied contracts. 15 O.S. § 131.",
            "date": "2012-09-30",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-skycam-implied-contract"
          },
          {
            "id": "skycam-claim-scope",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Skycam, LLC v. Bennett",
            "citation": "Skycam, LLC v. Bennett, 900 F. Supp. 2d 1264 (N.D. Okla. 2012).",
            "url": "https://www.courtlistener.com/opinion/8719889/skycam-llc-v-bennett/",
            "deepLink": "https://www.courtlistener.com/opinion/8719889/skycam-llc-v-bennett/#:~:text=Because%20Bennett%20was%20not%20employed,of%20the%20invention%20described%20therein.",
            "proposition": "Skycam, LLC v. Bennett shows the claim-scope limit of the hired-to-invent exception — the court found an employed-to-invent relationship yet denied the employer ownership because the employee was not employed to invent the entirety of the patent claim at issue.",
            "verbatimQuote": "Because Bennett was not employed to invent the entirety of the aerial camera system described in independent Claim 1, the court concludes Skycam is not entitled to ownership of the invention described therein.",
            "date": "2012-09-30",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-skycam-claim-scope"
          }
        ]
      },
      {
        "slug": "holdover-clause-limit",
        "label": "Are post-employment trailing-assignment clauses enforceable?",
        "heading": "Are trailing-assignment (holdover) clauses enforceable in Oklahoma?",
        "answerText": "Untested — and the framework a court would apply is statutory voidness, not reasonableness balancing. No Oklahoma decision found in our review addresses a post-employment trailing-assignment clause. The statute such a clause would be tested under is 15 O.S. § 217, which voids a contract restraining anyone from exercising a lawful profession, trade or business to that extent, outside a short list of statutory safe harbors that no invention assignment fits. Section 219A(B) separately voids any employment-contract provision in conflict with the customer non-solicitation regime, and Oklahoma courts strike an out-of-band covenant rather than narrowing it to something enforceable.",
        "sources": [
          {
            "id": "ok-217-restraint-void",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 217",
            "citation": "Okla. Stat. tit. 15, § 217.",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 217 voids any contract that restrains a person from exercising a lawful profession, trade, or business to that extent, outside the statutory safe harbors — the void-outright framework a post-employment trailing-assignment clause that functions as a restraint would be tested under.",
            "verbatimQuote": "Every contract by which any one is restrained from exercising a lawful profession, trade or business of any kind, otherwise than as provided by Sections 218 and 219 of this title, or otherwise than as provided by Section 2 of this act, is to that extent void.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-ok-217-restraint-void"
          },
          {
            "id": "ok-219a-direct-solicit",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 219A",
            "citation": "Okla. Stat. tit. 15, § 219A(A).",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 219A(A) is the employment safe harbor, and it is narrow — a former employee may be barred only from directly soliciting the established customers of the former employer, a permission a trailing invention-assignment clause does not fit.",
            "verbatimQuote": "A person who makes an agreement with an employer, whether in writing or verbally, not to compete with the employer after the employment relationship has been terminated, shall be permitted to engage in the same business as that conducted by the former employer or in a similar business as that conducted by the former employer as long as the former employee does not directly solicit the sale of goods, services or a combination of goods and services from the established customers of the former employer.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-ok-219a-direct-solicit"
          },
          {
            "id": "ok-219a-void-clause",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 219A",
            "citation": "Okla. Stat. tit. 15, § 219A(B).",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 219A(B) affirmatively voids any employment-contract provision in conflict with the statute — the overlay that strikes conflicting covenant language in an employment agreement directly.",
            "verbatimQuote": "Any provision in a contract between an employer and an employee in conflict with the provisions of this section shall be void and unenforceable.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-ok-219a-void-clause"
          },
          {
            "id": "ok-219b-not-a-restraint",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 219B",
            "citation": "Okla. Stat. tit. 15, § 219B.",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 219B shows the Legislature's template for taking a covenant type outside § 217 — a qualifying anti-raiding clause shall not be construed as a restraint from exercising a lawful profession — and no comparable exemption exists for trailing invention assignments.",
            "verbatimQuote": "A contract or contractual provision which prohibits an employee or independent contractor of a person or business from soliciting, directly or indirectly, actively or inactively, the employees or independent contractors of that person or business to become employees or independent contractors of another person or business shall not be construed as a restraint from exercising a lawful profession, trade or business of any kind.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-ok-219b-not-a-restraint"
          },
          {
            "id": "howard-restraints-void",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Howard v. Nitro-Lift Technologies, L.L.C.",
            "citation": "Howard v. Nitro-Lift Techs., L.L.C., 2011 OK 98, 273 P.3d 20, vacated on other grounds sub nom. Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17 (2012).",
            "url": "https://www.courtlistener.com/opinion/5327051/howard-v-nitro-lift-technologies-llc/",
            "deepLink": "https://www.courtlistener.com/opinion/5327051/howard-v-nitro-lift-technologies-llc/#:~:text=The%20non%2Dcompetition%20contracts%20go%20well,the%20legislatively%20expressed%20public%20policy.",
            "proposition": "Howard reflects Oklahoma's rule that covenants exceeding what § 219A allows are void as against the legislatively expressed public policy — the decision was vacated on arbitration-procedure grounds, but the statutory rule it applied remains good law.",
            "verbatimQuote": "The non-competition contracts go well beyond the bounds of what is allowable under § 219A and violate the legislatively expressed public policy.",
            "date": "2011-11-22",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-howard-restraints-void"
          },
          {
            "id": "autry-no-sever",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Autry v. Acosta, Inc.",
            "citation": "Autry v. Acosta, Inc., 2018 OK CIV APP 8, 410 P.3d 1017.",
            "url": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/",
            "deepLink": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/#:~:text=We%20find%20that%20the%20remedy,merely%20deleting%20the%20word%20%22indirectly.%22",
            "proposition": "Autry holds that an overbroad covenant cannot be brought into compliance with § 219A by deleting the offending word — Oklahoma courts refuse even single-word severance, so an overbroad holdover clause faces invalidation, not judicial narrowing.",
            "verbatimQuote": "We find that the remedy for this Non-Solicitation Agreement's shortcomings is not quite that simple and it cannot be made to comply with § 219A by merely deleting the word \"indirectly.\"",
            "date": "2017-11-14",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-autry-no-sever"
          },
          {
            "id": "autry-void",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Autry v. Acosta, Inc.",
            "citation": "Autry v. Acosta, Inc., 2018 OK CIV APP 8, 410 P.3d 1017.",
            "url": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/",
            "deepLink": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/#:~:text=Examined%20under%20the%20lens%20of,Legislature's%20enactment%20of%20that%20section.",
            "proposition": "Autry holds that the overbroad covenant was void and unenforceable as against Oklahoma public policy under § 219A — the disposition for an out-of-band covenant is voidness, not reformation.",
            "verbatimQuote": "Examined under the lens of § 219A, the Non-Solicitation Agreement is void and unenforceable as against Oklahoma's public policy expressed by the Legislature's enactment of that section.",
            "date": "2017-11-14",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-autry-void"
          },
          {
            "id": "inergy-rule-of-reason",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Inergy Propane, LLC v. Lundy",
            "citation": "Inergy Propane, LLC v. Lundy, 2009 OK CIV APP 8, 219 P.3d 547.",
            "url": "https://www.courtlistener.com/opinion/2629577/inergy-propane-llc-v-lundy/",
            "deepLink": "https://www.courtlistener.com/opinion/2629577/inergy-propane-llc-v-lundy/#:~:text=That%20does%20not%2C%20however%2C%20require,by%20previously%20established%20case%20law.",
            "proposition": "Inergy Propane, LLC v. Lundy holds that § 219A did not abandon the common-law rule of reason for covenants within the statutory safe harbor — reasonableness in Oklahoma is a filter inside a statutory permission, not a rescue doctrine for restraints outside it.",
            "verbatimQuote": "That does not, however, require abandonment of the rule of reason analysis required by previously established case law.",
            "date": "2008-08-13",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-inergy-rule-of-reason"
          },
          {
            "id": "ok-217-void-practice",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 217",
            "citation": "Okla. Stat. tit. 15, § 217.",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 217 voids a covered restraint to that extent — invalidation of the offending reach rather than reformation — so an untethered holdover clause characterized as a restraint falls rather than being trimmed.",
            "verbatimQuote": "Every contract by which any one is restrained from exercising a lawful profession, trade or business of any kind, otherwise than as provided by Sections 218 and 219 of this title, or otherwise than as provided by Section 2 of this act, is to that extent void.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-ok-217-void-practice"
          },
          {
            "id": "autry-no-sever-practice",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Autry v. Acosta, Inc.",
            "citation": "Autry v. Acosta, Inc., 2018 OK CIV APP 8, 410 P.3d 1017.",
            "url": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/",
            "deepLink": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/#:~:text=We%20find%20that%20the%20remedy,merely%20deleting%20the%20word%20%22indirectly.%22",
            "proposition": "Autry refused to save an overbroad covenant by deleting even a single offending word — a drafter cannot count on an Oklahoma court preserving a less burdensome version of an overbroad trailing clause.",
            "verbatimQuote": "We find that the remedy for this Non-Solicitation Agreement's shortcomings is not quite that simple and it cannot be made to comply with § 219A by merely deleting the word \"indirectly.\"",
            "date": "2017-11-14",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-autry-no-sever-practice"
          },
          {
            "id": "eakle-choice-of-law-practice",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Eakle v. Grinnell Corp.",
            "citation": "Eakle v. Grinnell Corp., 272 F. Supp. 2d 1304 (E.D. Okla. 2003).",
            "url": "https://www.courtlistener.com/opinion/2296282/eakle-v-grinnell-corp/",
            "deepLink": "https://www.courtlistener.com/opinion/2296282/eakle-v-grinnell-corp/#:~:text=As%20this%20general%20rule%20recognizes%2C,policy%20of%20the%20forum%20state.",
            "proposition": "Eakle states that an Oklahoma forum court will not apply a contractually chosen foreign law where doing so would violate Oklahoma public policy — a foreign governing-law clause does not give a trailing-assignment clause room Oklahoma's restraint statute denies it.",
            "verbatimQuote": "As this general rule recognizes, however, the forum court will not apply the law chosen by the contracting parties should doing so violate the public policy of the forum state.",
            "date": "2003-06-11",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-eakle-choice-of-law-practice"
          },
          {
            "id": "ok-219a-void-clause-practice",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 219A",
            "citation": "Okla. Stat. tit. 15, § 219A(B).",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 219A(B) voids any employment-contract provision in conflict with the statute by its own force — the conflicting clause is void and unenforceable regardless of what law the contract selects.",
            "verbatimQuote": "Any provision in a contract between an employer and an employee in conflict with the provisions of this section shall be void and unenforceable.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/oklahoma#src-ok-219a-void-clause-practice"
          }
        ]
      }
    ]
  }
}