In Kanan, Corbin, Schupak & Aronow, Inc. v. FD Intl., Ltd., 8 Misc 3d 412 (Sup. Ct. NY Cnty. 2005) the court considered the enforceability of restrictive covenants contained in the employment agreements of two former employees of a public relations firm. Kanan, 8 Misc 3d at 413. In Kanan, "the restrictive covenants contained in the . . . agreements really [sought] to protect the good will' of the clients developed during the defendants' tenure of . . . employment with the plaintiff." Kanan, 8 Misc 3d at 418. Ultimately, the court in Kanan denied plaintiff's motion for a preliminary injunction. In reaching its conclusion, the court observed that where there is a triable issue of fact regarding the goodwill, at least "a minimal showing is required in support of the proposition that the goodwill allegedly misappropriated was created at the employer's expense." Kanan, 8 Misc 3d at 419-20.