The National Labor Relations Board (NLRB) General Counsel, Jennifer Abruzzo, has intensified her stance against noncompete agreements, declaring that 'stay-or-pay' provisions are unlawful. Abruzzo is advocating for make-whole remedies for employees affected by such provisions, which she argues violate the National Labor Relations Act (NLRA). This follows a recent ruling by the U.S. Court of Appeals for the First Circuit, which stated that California's statutory ban on noncompete agreements does not supersede Massachusetts law that allows these agreements if the employee has never worked in California. The implications of these legal interpretations could significantly impact the enforceability of noncompete agreements across state lines. Additionally, discussions are emerging regarding the potential for courts to impose double or triple nominal damages for willful violations of Massachusetts law concerning unfair trade practices, specifically Chapter 93A, Section 9. The Massachusetts Appeals Court has also clarified that an 'unseemly' contract breach does not automatically trigger liability under Chapter 93A.