{
  "type": "practice-guide",
  "canonical": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming",
  "links": [
    {
      "rel": "self",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming.json",
      "type": "application/json"
    },
    {
      "rel": "alternate",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming",
      "type": "text/html"
    },
    {
      "rel": "alternate",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming/markdown",
      "type": "text/markdown"
    },
    {
      "rel": "alternate",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming/json",
      "type": "application/json"
    }
  ],
  "data": {
    "topic": "invention-assignment",
    "state": "wyoming",
    "frontmatter": {
      "title": "Employee Invention Assignment in Wyoming",
      "description": "Wyoming has no employee-invention-assignment statute — the only appearance of the word invention in the Wyoming Statutes sits inside the criminal-code trade-secret definition — so an assignment clause is bounded by ordinary contract law, the common-law defaults the Wyoming Supreme Court adopted in Preston v. Marathon Oil Co. (inventor owns unless hired to invent, plus an employer shop right), and restraint-of-trade limits. Continued at-will employment is sufficient consideration for an assignment agreement, and for contracts entered into on or after July 1, 2025 a holdover clause that operates as a covenant not to compete risks voidness under Wyo. Stat. § 1-23-108 unless a statutory exception applies.",
      "state": "Wyoming",
      "lastReviewed": "2026-07-03",
      "license": "CC BY 4.0",
      "authors": [
        "steven-obiajulu"
      ],
      "summary": {
        "bottomLine": "Wyoming has no employee-invention-assignment statute — the word invention appears in the Wyoming Statutes only inside the criminal-code trade-secret definition — so an assignment clause is bounded by ordinary contract law, the common-law defaults the Wyoming Supreme Court adopted in Preston v. Marathon Oil Co. (inventor owns unless hired to invent, plus an employer shop right), and restraint-of-trade limits; continued at-will employment is sufficient consideration for an assignment agreement, an agreement containing a one-year post-termination presumption clause has been enforced under restraint-of-trade reasoning, and for contracts entered into on or after July 1, 2025 a holdover clause that operates as a covenant not to compete is void under Wyo. Stat. § 1-23-108 unless the trade-secret or executive-and-management exceptions apply, with no blue-pencil rescue after Hassler.",
        "keyLaw": "No Wyoming invention-assignment statute; Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012); Wyo. Stat. § 1-23-108 (2025)",
        "statutoryCarveOut": "none",
        "defaultOwnership": "employee",
        "employeeNoticeRequired": "n/a",
        "holdoverClauseLimit": "reasonablenessOnly",
        "carveOutScope": "Wyoming has no statutory own-time carve-out; the reach of an assignment clause is limited by ordinary contract law, the common-law inventor-owns default with the hired-to-invent exception and the employer's shop right (Preston v. Marathon Oil Co.), the federal patent and copyright overlay, and — for contracts entered into on or after July 1, 2025 — the restraint-of-trade framework of Wyo. Stat. § 1-23-108 where a clause functions as a covenant not to compete."
      },
      "about": [
        "Wyoming invention assignment",
        "Wyoming no invention-assignment statute",
        "Wyoming employee invention ownership",
        "Preston v. Marathon Oil Co.",
        "Wyoming hired to invent",
        "Wyoming shop right",
        "Wyoming holdover trailing assignment",
        "Wyo. Stat. § 1-23-108 covenant not to compete"
      ],
      "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 a Wyoming employer require assignment of every invention?",
        "answerText": "There is no statutory ceiling. Wyoming has no employee-invention-assignment statute — nothing that voids an assignment of a true own-time, own-resource invention the way California Labor Code § 2870 does — so an assignment clause's reach is bounded by ordinary contract law, the common-law inventor-owns default, and the federal patent and copyright overlay. The Wyoming Supreme Court's employee-invention decision, Preston v. Marathon Oil Co., starts from the rule that an invention belongs to its inventor unless the inventor has contracted it away.",
        "sources": [
          {
            "id": "preston-inventor-default",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co.",
            "citation": "Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012).",
            "url": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/#:~:text=Generally%20an%20invention%20is%20the,she%20has%20contracted%20them%20away.",
            "proposition": "Preston v. Marathon Oil Co. adopts the general rule that an invention is the property of the inventor unless he or she has contracted those rights away — the baseline any Wyoming assignment clause operates against.",
            "verbatimQuote": "Generally an invention is the property of the inventor who conceived, developed, and perfected it, and the law protects and enforces the inventor's property rights in an invention unless he or she has contracted them away.",
            "date": "2012-05-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-inventor-default"
          },
          {
            "id": "wyo-6-3-501-invention-only-mention",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "Wyo. Stat. § 6-3-501(a)(xi)",
            "citation": "Wyo. Stat. § 6-3-501(a)(xi).",
            "url": "https://wyoleg.gov/statutes/compress/title06.pdf",
            "proposition": "Wyo. Stat. § 6-3-501(a)(xi), the criminal-code trade-secret definition, is the only provision of the Wyoming Statutes that mentions invention at all — evidence that Wyoming has no employee-invention-assignment statute.",
            "verbatimQuote": "\"Trade secret\" means the whole or a portion or phase of a formula, pattern, device, combination of devices or compilation of information which is for use, or is used in the operation of a business and which provides the business an advantage or an opportunity to obtain an advantage over those who do not know or use it.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-wyo-6-3-501-invention-only-mention"
          },
          {
            "id": "preston-continued-employment-consideration",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co.",
            "citation": "Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012).",
            "url": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/#:~:text=no%20additional%20consideration%20is%20required,intellectual%20property%20to%20his%20employer.",
            "proposition": "Preston v. Marathon Oil Co. answers the certified question yes — continued at-will employment is sufficient consideration for an intellectual-property-assignment agreement signed by an existing employee, with no additional consideration required.",
            "verbatimQuote": "no additional consideration is required to support an employee's post-employment execution of an agreement to assign intellectual property to his employer.",
            "date": "2012-05-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-continued-employment-consideration"
          },
          {
            "id": "hopper-separate-consideration",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Hopper v. All Pet Animal Clinic, Inc.",
            "citation": "Hopper v. All Pet Animal Clinic, Inc., 861 P.2d 531 (Wyo. 1993).",
            "url": "https://www.courtlistener.com/opinion/1158134/hopper-v-all-pet-animal-clinic-inc/",
            "deepLink": "https://www.courtlistener.com/opinion/1158134/hopper-v-all-pet-animal-clinic-inc/#:~:text=We%20believe%20strong%20public%20policy%20favors%20separate%20consideration.",
            "proposition": "Hopper v. All Pet Animal Clinic states Wyoming's separate-consideration rule for non-competes signed by existing employees — the rule Preston declined to extend to intellectual-property assignments.",
            "verbatimQuote": "We believe strong public policy favors separate consideration.",
            "date": "1993-10-01",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-hopper-separate-consideration"
          }
        ]
      },
      {
        "slug": "employee-notice",
        "label": "Must the employer give the employee written notice of the carve-out?",
        "heading": "Must a Wyoming employer notify the employee?",
        "answerText": "Not applicable. Because Wyoming 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). What Wyoming enforces is contractual — an employee's assignment obligations exist only to the extent the employee has contracted invention rights away.",
        "sources": [
          {
            "id": "preston-contract-based-duties",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co.",
            "citation": "Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012).",
            "url": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/#:~:text=Generally%20an%20invention%20is%20the,she%20has%20contracted%20them%20away.",
            "proposition": "Preston v. Marathon Oil Co. treats employee-invention ownership as contractual — the inventor owns unless rights are contracted away — so in Wyoming any disclosure or assignment duty arises from the agreement itself rather than from a notice-requiring statute.",
            "verbatimQuote": "Generally an invention is the property of the inventor who conceived, developed, and perfected it, and the law protects and enforces the inventor's property rights in an invention unless he or she has contracted them away.",
            "date": "2012-05-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-contract-based-duties"
          }
        ]
      },
      {
        "slug": "default-ownership",
        "label": "Absent a written assignment, who owns the invention?",
        "heading": "Who owns an invention by default in Wyoming?",
        "answerText": "The inventor, unless hired to invent. Wyoming does not leave this to analogy — in Preston v. Marathon Oil Co. the Wyoming Supreme Court itself adopted the inventor-owns default, with the hired-to-invent rule and the employer's shop right as the exceptions, matching the baseline of federal patent law.",
        "sources": [
          {
            "id": "preston-inventor-default-rule",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co.",
            "citation": "Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012).",
            "url": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/#:~:text=Generally%20an%20invention%20is%20the,she%20has%20contracted%20them%20away.",
            "proposition": "Preston v. Marathon Oil Co. adopts the inventor-owns default for Wyoming — absent a contract assigning them away, invention rights belong to the employee who conceived, developed, and perfected the invention.",
            "verbatimQuote": "Generally an invention is the property of the inventor who conceived, developed, and perfected it, and the law protects and enforces the inventor's property rights in an invention unless he or she has contracted them away.",
            "date": "2012-05-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-inventor-default-rule"
          },
          {
            "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 same baseline the Wyoming Supreme Court adopted in Preston.",
            "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/wyoming#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. holds that an employee hired to make an invention who succeeds during the term of service is bound to assign the resulting patent to the employer — the hired-to-invent exception to the inventor-owns default.",
            "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/wyoming#src-dubilier-hired-to-invent"
          },
          {
            "id": "preston-shop-right-scope",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co.",
            "citation": "Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012) (quoting 27 Am. Jur. 2d Employment Relationship § 188 (2011)).",
            "url": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/#:~:text=Where%20the%20employee%20is%20not,invention%20under%20the%20shop%2Dright%20rule.",
            "proposition": "Preston v. Marathon Oil Co., quoting 27 Am. Jur. 2d Employment Relationship § 188, adopts the shop-right rule for Wyoming — an employee not hired to invent who conceives a device at work with the employer's materials gives the employer an irrevocable but nonexclusive right to use the invention.",
            "verbatimQuote": "Where the employee is not hired specifically to design or invent, but nevertheless conceives of a device during working hours with the use of the employer's materials and equipment, the employer is granted an irrevocable but nonexclusive right to use the invention under the shop-right rule.",
            "date": "2012-05-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-shop-right-scope"
          },
          {
            "id": "preston-shop-right-not-ownership",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co.",
            "citation": "Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012) (quoting 27 Am. Jur. 2d Employment Relationship § 188 (2011)).",
            "url": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/#:~:text=Notwithstanding%20the%20existence%20of%20the,the%20benefits%20of%20the%20invention.",
            "proposition": "Preston v. Marathon Oil Co., quoting 27 Am. Jur. 2d Employment Relationship § 188, confirms that a shop right is only a license — the invention remains the property of the employee, who may exclude everyone but the employer.",
            "verbatimQuote": "Notwithstanding the existence of the shop right, the invention remains the property of the employee, and the employee has the right, conferred by the patent, to exclude all but the employer from the benefits of the invention.",
            "date": "2012-05-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-shop-right-not-ownership"
          },
          {
            "id": "preston-fedcir-present-assignment",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co. (Fed. Cir.)",
            "citation": "Preston v. Marathon Oil Co., 684 F.3d 1276 (Fed. Cir. 2012).",
            "url": "https://www.courtlistener.com/opinion/803959/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/803959/preston-v-marathon-oil-co/#:~:text=it%20is%20an%20express%20assignment,need%20for%20any%20additional%20act.",
            "proposition": "The Federal Circuit's companion Preston decision, applying Wyoming's certified answer, holds that hereby-assign language is an express present assignment of future inventions that transfers rights automatically, without any additional act.",
            "verbatimQuote": "it is an express assignment of rights in future inventions that automatically assigned rights to Marathon without the need for any additional act.",
            "date": "2012-07-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-fedcir-present-assignment"
          }
        ]
      },
      {
        "slug": "holdover-clause-limit",
        "label": "Are post-employment trailing-assignment clauses enforceable?",
        "heading": "Are trailing-assignment (holdover) clauses enforceable in Wyoming?",
        "answerText": "Reasonableness is the operative limit, and since July 1, 2025 the answer also depends on when the contract was signed. No Wyoming statute addresses invention holdover clauses specifically, but Preston v. Marathon Oil Co. enforced an assignment agreement containing a one-year post-termination presumption clause, reasoning that the assignment imposed no improper restraint on trade — so restraint-of-trade scrutiny is the frame when a trailing clause does restrain. For contracts entered into on or after July 1, 2025, a holdover clause that operates as a covenant not to compete is void under Wyo. Stat. § 1-23-108(a) unless a statutory exception applies.",
        "sources": [
          {
            "id": "preston-holdover-presumption",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co.",
            "citation": "Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012).",
            "url": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/#:~:text=The%20assignment%20agreement%20also%20did,or%20conceived%20during%22%20his%20employment.",
            "proposition": "Preston v. Marathon Oil Co. describes the enforced agreement's one-year post-termination clause as a presumption about when inventions were conceived and emphasizes that the agreement did not reach inventions created after employment ended — Wyoming's closest trailing-clause authority.",
            "verbatimQuote": "The assignment agreement also did not affect Mr. Preston's rights to inventions he created after his employment with Marathon was over, although intellectual property conceived or made by him within one year after termination was \"presumed to have been made or conceived during\" his employment.",
            "date": "2012-05-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-holdover-presumption"
          },
          {
            "id": "preston-assignment-not-restraint",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co.",
            "citation": "Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012).",
            "url": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/#:~:text=Given%20that%20the%20intellectual%20property,our%20decision%20in%20this%20case.",
            "proposition": "Preston v. Marathon Oil Co. reasons that an intellectual-property assignment that does not affect the employee's right to earn a living or restrain trade escapes Wyoming's non-compete rules — making restraint-of-trade scrutiny the operative frame when a trailing clause does restrain.",
            "verbatimQuote": "Given that the intellectual property assignment agreement did not affect Mr. Preston's right to earn a living or otherwise impose an improper restraint on trade, Hopper does not govern our decision in this case.",
            "date": "2012-05-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-assignment-not-restraint"
          },
          {
            "id": "hopper-reasonableness-elements",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Hopper v. All Pet Animal Clinic, Inc.",
            "citation": "Hopper v. All Pet Animal Clinic, Inc., 861 P.2d 531 (Wyo. 1993).",
            "url": "https://www.courtlistener.com/opinion/1158134/hopper-v-all-pet-animal-clinic-inc/",
            "deepLink": "https://www.courtlistener.com/opinion/1158134/hopper-v-all-pet-animal-clinic-inc/#:~:text=A%20valid%20and%20enforceable%20covenant,(5)%20not%20against%20public%20policy.",
            "proposition": "Hopper v. All Pet Animal Clinic states Wyoming's common-law reasonableness elements for covenants not to compete — the framework governing pre-July 1, 2025 contracts and any holdover clause analyzed as a restraint.",
            "verbatimQuote": "A valid and enforceable covenant not to compete requires a showing that the covenant is: (1) in writing; (2) part of a contract of employment; (3) based on reasonable consideration; (4) reasonable in durational and geographical limitations; and (5) not against public policy.",
            "date": "1993-10-01",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-hopper-reasonableness-elements"
          },
          {
            "id": "wyo-1-23-108-void-labor",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "Wyo. Stat. § 1-23-108(a)",
            "citation": "Wyo. Stat. § 1-23-108(a) (2025) (SF 107, Enrolled Act No. 87).",
            "url": "https://wyoleg.gov/2025/Enroll/SF0107.pdf",
            "proposition": "Wyo. Stat. § 1-23-108(a) voids covenants not to compete that restrict any person's right to receive compensation for skilled or unskilled labor, for contracts entered into on or after July 1, 2025 — the statutory layer a post-2025 holdover clause must clear if it operates as a covenant not to compete.",
            "verbatimQuote": "Any covenant not to compete that restricts the right of any person to receive compensation for performance of skilled or unskilled labor shall be void.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-wyo-1-23-108-void-labor"
          },
          {
            "id": "sf107-savings-clause",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "SF 107 § 2(b)",
            "citation": "S.F. 107, Enrolled Act No. 87, § 2(b), 68th Leg., Gen. Sess. (Wyo. 2025).",
            "url": "https://wyoleg.gov/2025/Enroll/SF0107.pdf",
            "proposition": "SF 107 § 2(b) preserves contracts entered into before July 1, 2025, so pre-2025 assignment agreements and holdover clauses continue to be analyzed under Wyoming common law.",
            "verbatimQuote": "Nothing in this act shall be construed to alter, amend or impair any contract or agreement entered into before July 1, 2025.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-sf107-savings-clause"
          },
          {
            "id": "wyo-1-23-108-trade-secret-exception",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "Wyo. Stat. § 1-23-108(a)(ii)",
            "citation": "Wyo. Stat. § 1-23-108(a)(ii) (2025) (SF 107, Enrolled Act No. 87).",
            "url": "https://wyoleg.gov/2025/Enroll/SF0107.pdf",
            "proposition": "Wyo. Stat. § 1-23-108(a)(ii) exempts covenants to the extent they protect trade secrets as defined by the criminal-code definition in W.S. 6-3-501(a)(xi) — the trade-secret path for a post-2025 holdover clause.",
            "verbatimQuote": "Any covenant not to compete to the extent the covenant provides for the protection of trade secrets as defined by W.S. 6-3-501(a)(xi);",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-wyo-1-23-108-trade-secret-exception"
          },
          {
            "id": "wyo-1-23-108-executive-exception",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "Wyo. Stat. § 1-23-108(a)(iv)",
            "citation": "Wyo. Stat. § 1-23-108(a)(iv) (2025) (SF 107, Enrolled Act No. 87).",
            "url": "https://wyoleg.gov/2025/Enroll/SF0107.pdf",
            "proposition": "Wyo. Stat. § 1-23-108(a)(iv) exempts executive and management personnel and their professional staff from the statutory void rule — materially narrowing the ban for the senior R&D population most likely to face holdover clauses.",
            "verbatimQuote": "Executive and management personnel and officers and employees who constitute professional staff to executive and management personnel.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-wyo-1-23-108-executive-exception"
          },
          {
            "id": "hassler-no-blue-pencil",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Hassler v. Circle C Resources",
            "citation": "Hassler v. Circle C Resources, 2022 WY 28, 505 P.3d 169 (Wyo. 2022).",
            "url": "https://www.courtlistener.com/opinion/9998701/charlene-hassler-v-circle-c-resources/",
            "deepLink": "https://www.courtlistener.com/opinion/9998701/charlene-hassler-v-circle-c-resources/#:~:text=We%20conclude%20it%20is%20no,to%20modify%20unreasonable%20noncompete%20agreements.",
            "proposition": "Hassler v. Circle C Resources abolishes blue-pencil modification in Wyoming — an unreasonable restraint is void in its entirety, not judicially trimmed, which sets the downside for an overbroad holdover clause characterized as a restraint.",
            "verbatimQuote": "We conclude it is no longer tenable for courts to use the blue pencil rule to modify unreasonable noncompete agreements.",
            "date": "2022-02-25",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-hassler-no-blue-pencil"
          },
          {
            "id": "wyo-6-3-501-definition-practice",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "Wyo. Stat. § 6-3-501(a)(xi)",
            "citation": "Wyo. Stat. § 6-3-501(a)(xi).",
            "url": "https://wyoleg.gov/statutes/compress/title06.pdf",
            "proposition": "Wyo. Stat. § 6-3-501(a)(xi) supplies the criminal-code trade-secret definition that the § 1-23-108(a)(ii) exception incorporates — the definition a trade-secret-tied holdover clause must actually track.",
            "verbatimQuote": "\"Trade secret\" means the whole or a portion or phase of a formula, pattern, device, combination of devices or compilation of information which is for use, or is used in the operation of a business and which provides the business an advantage or an opportunity to obtain an advantage over those who do not know or use it.",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-wyo-6-3-501-definition-practice"
          },
          {
            "id": "preston-fedcir-present-assignment-practice",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co. (Fed. Cir.)",
            "citation": "Preston v. Marathon Oil Co., 684 F.3d 1276 (Fed. Cir. 2012).",
            "url": "https://www.courtlistener.com/opinion/803959/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/803959/preston-v-marathon-oil-co/#:~:text=it%20is%20an%20express%20assignment,need%20for%20any%20additional%20act.",
            "proposition": "The Federal Circuit's companion Preston decision holds that hereby-assign language is an express present assignment of future inventions that transfers rights automatically, without any additional act.",
            "verbatimQuote": "it is an express assignment of rights in future inventions that automatically assigned rights to Marathon without the need for any additional act.",
            "date": "2012-07-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-fedcir-present-assignment-practice"
          },
          {
            "id": "preston-consideration-practice",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Preston v. Marathon Oil Co.",
            "citation": "Preston v. Marathon Oil Co., 2012 WY 66, 277 P.3d 81 (Wyo. 2012).",
            "url": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/",
            "deepLink": "https://www.courtlistener.com/opinion/2330166/preston-v-marathon-oil-co/#:~:text=no%20additional%20consideration%20is%20required,intellectual%20property%20to%20his%20employer.",
            "proposition": "Preston v. Marathon Oil Co. holds that continued at-will employment is sufficient consideration for an intellectual-property-assignment agreement, with no additional consideration required.",
            "verbatimQuote": "no additional consideration is required to support an employee's post-employment execution of an agreement to assign intellectual property to his employer.",
            "date": "2012-05-10",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-preston-consideration-practice"
          },
          {
            "id": "hopper-separate-consideration-practice",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Hopper v. All Pet Animal Clinic, Inc.",
            "citation": "Hopper v. All Pet Animal Clinic, Inc., 861 P.2d 531 (Wyo. 1993).",
            "url": "https://www.courtlistener.com/opinion/1158134/hopper-v-all-pet-animal-clinic-inc/",
            "deepLink": "https://www.courtlistener.com/opinion/1158134/hopper-v-all-pet-animal-clinic-inc/#:~:text=We%20believe%20strong%20public%20policy%20favors%20separate%20consideration.",
            "proposition": "Hopper v. All Pet Animal Clinic requires separate consideration for a non-compete signed by an existing employee — a rule that survives Hassler and still governs the restraint half of a hybrid agreement.",
            "verbatimQuote": "We believe strong public policy favors separate consideration.",
            "date": "1993-10-01",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/wyoming#src-hopper-separate-consideration-practice"
          }
        ]
      }
    ]
  }
}