The Illinois Appellate recently affirmed a two-year bright-line continued employment rule for adequate consideration in non-compete cases if the only consideration is continued employment. Many, but not all, of the federal district courts in Illinois, do not follow this bright-line rule predicting that the Illinois Supreme Court will not follow it. The Illinois Supreme Court has not yet addressed the issue. You can read the most recent Illinois Appellate decision here. You can also listen below to the oral argument held in the Appellate Court before it reached this decision: