In Dowell v. Biosense Webster, Inc. (2009) 179 Cal.App.4th 564, an appellate court held that a broadly worded noncompete clause was a facially void restriction on employees' practice of their chosen profession, where the clause prohibited employees, for a period of 18 months after termination of employment, from rendering services, directly or indirectly, to any competitor in which the services they might provide could enhance the use or marketability of a conflicting product by application of confidential information to which the employees had access during employment. (Id. at pp. 575, 577-578.) There, the employer argued that the noncompete clause was valid because it was tailored to protect trade secrets. (Id. at pp. 575-576.) After discussing the questionable viability of the trade secret exceptions to covenants not to compete, the court held that, even assuming this common law exception still exists, the clause was not "narrowly tailored" or "carefully limited" to the protection of trade secrets. (Id. at pp. 576-579.)