Payscale Inc. v. Erin Norman and BetterComp, Inc.

CourtSupreme Court of Delaware
DecidedMarch 19, 2026
Docket297, 2025
StatusPublished

This text of Payscale Inc. v. Erin Norman and BetterComp, Inc. (Payscale Inc. v. Erin Norman and BetterComp, Inc.) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Payscale Inc. v. Erin Norman and BetterComp, Inc., (Del. 2026).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

PAYSCALE INC., § § No. 297, 2025 Plaintiff Below, § Appellant, § § Court Below: Court of Chancery v. § of the State of Delaware § ERIN NORMAN and § C.A. No. 2025-0118 BETTERCOMP, INC., § § Defendants Below, § Appellee. §

Submitted: January 14, 2026 Decided: March 19, 2026

Before SEITZ, Chief Justice; TRAYNOR and LEGROW, Justices.

Upon appeal from the Court of Chancery of the State of Delaware. REVERSED and REMANDED.

Steven L. Caponi (argued), Esquire, and Megan E. Hunt, Esquire, K&L GATES LLP, Wilmington, Delaware, for Appellant Payscale, Inc.

John A. Sensing (argued), Esquire, Jesse L. Noa, Esquire, Tyler E. Cragg, Esquire, and Hannah L. Paxton, Esquire, POTTER ANDERSON & CORROON LLP, Wilmington, Delaware, for Appellee Erin Norman and BetterComp, Inc.

LEGROW, Justice: The Court of Chancery dismissed an employer’s effort to enforce several

restrictive covenants, holding that the non-compete clause was unenforceable and

the employer’s allegations relating to breaches of the non-solicitation and

confidentiality clauses were conclusory. We hold that the court’s reasoning rested

on inferences it improperly drew against the employer at the pleading stage, and we

therefore reverse the court’s judgment. Our holding is limited to whether the

employer stated a reasonably conceivable claim for relief; we express no view on

whether any covenant ultimately will be enforced, reformed, or held unenforceable

on a more developed record.

Payscale Inc. filed suit in the Court of Chancery upon learning that its former

employee, Erin Norman, had joined a competitor, BetterComp, Inc. After the court

denied a temporary restraining order and granted a motion to expedite, Norman and

BetterComp jointly moved to dismiss Payscale’s amended complaint, which alleged

claims for breach of contract and tortious interference with contractual and

prospective business relations.

The non-compete clause at issue had a nationwide, eighteen-month scope.

The Court of Chancery correctly approached that restriction with skepticism, noting

that Delaware courts rarely enforce such broad restrictions against employees. But

notwithstanding Payscale’s detailed allegations regarding its nationwide operations,

Norman’s role at the company, her involvement in key company-wide strategic

1 decisions, and the client-driven reasons necessitating the duration of the restriction,

the court held that it was not reasonably conceivable that the non-compete’s scope

was enforceable in light of the minimal value that the court ascribed to the equity

units that Norman received as consideration. That holding, in our view, misapplied

Delaware’s low pleading burden.

As to the non-solicitation and confidentiality clauses, the court dismissed as

conclusory Payscale’s allegations that in the two months since Norman had joined

the competitor, at least five clients had followed her—numbers that were not typical

in the business. The court’s opinion did not address those allegations, which support

a reasonable inference that Norman solicited clients or disclosed confidential

information that permitted BetterComp to unfairly compete.

The court’s conclusions that the non-compete was facially unenforceable and

that Payscale had not adequately pleaded breaches of the other covenants

prematurely weighed the facts and drew inferences against the non-moving party.

We therefore REVERSE the court’s judgment and REMAND for further

proceedings consistent with this opinion so that the court can evaluate these claims

on a more developed factual record.

2 I. In 2016, Norman was briefly employed by Payscale after her initial employer

merged with the company. She later left Payscale but returned in 2021 after it

acquired Norman’s then-employer.

About three months after rejoining Payscale, Norman entered into an

incentive equity agreement with Sonic Topco, L.P. (“Topco”), Payscale’s holding

company. The agreement bound Norman to restrictive covenants in exchange for

receiving 150,000 Topco “Profit Interest Units” (“PIUs”) in the form of “Service

Units” and “Performance Units.”1 Norman received twenty-five percent of the

Service Units on February 23, 2023, with the remaining Service Units scheduled to

vest periodically over the next three years.2 The Performance Units would only vest

upon the sale of Topco.3

1 App. to Opening Br. at A260 (Incentive Equity Agreement § 4(a)) (“The Profits Interest Units shall be subject to vesting in the manner specified in this Section 4. With respect to the Profits Interest Units issued hereunder, 75% shall be referred to as ‘Profits Interest Service Units’ and 25% shall be referred to as ‘Profits Interest Performance Units’. Profits Interest Units that have become vested are referred to herein as ‘Vested Profits Interest Units’. All Profits Interest Units that have not vested are referred to herein as ‘Unvested Profits Interest Units’.”) (underline and bold in original). For the sake of consistency, all citations will refer to the first incentive equity agreement. As noted below, Norman later entered into a second incentive equity agreement containing substantively identical covenants. 2 Id. (Incentive Equity Agreement § 4(b)) (“Recipient shall vest in (i) 25.0% of the Profits Interest Service Units on February 23, 2023 and the remainder shall vest monthly thereafter in equal amounts of the Profits Interest Service Units over the following three (3) year period thereafter (i.e., approximately 2.083% of the Profits Interest Service Units per month) . . . .”). 3 Id. (Incentive Equity Agreement § 4(b)) (“Recipient shall vest in . . . (ii) 100% of the Profits Interest Performance Units upon a Sale of the Partnership (each such date, a ‘Vesting Date’), in each case, so long as Recipient is and has remained an employee, officer, manager, director or consultant of the Partnership or one of its Subsidiaries from the date hereof through and including 3 The restrictive covenants in the incentive equity agreement include non-

compete, non-solicitation, and confidentiality provisions.4 The non-compete

provision prohibits Norman from engaging in “Competitive Activity” in the United

States for eighteen months after her separation from Payscale.5 The non-solicitation

provision prevents Norman from inducing any employees, clients, or other business

relations from leaving Topco or its subsidiaries.6 Norman is also barred from

disclosing confidential information to other entities or individuals.7

In February 2023, Norman was promoted to Senior Director of Sales,

overseeing Payscale’s sales in the western United States.8 About five months later,

Norman executed a second incentive equity agreement with Topco that contained

such Vesting Date. There shall be no proportional or partial vesting in the periods prior to each Vesting Date and all vesting should only occur on the applicable Vesting Date. Notwithstanding the foregoing, the Board may, in its sole discretion, provide for accelerated vesting of the Profits Interest Units at any time.”) (bold in original); see Answering Br. at 6–7. 4 App. to Opening Br. at A263–67 (Incentive Equity Agreement §§ 7 and 8). 5 Id. at A266 (Incentive Equity Agreement § 8(a)). “‘Competitive Business’ means any business conducted by the Partnership or any of its Subsidiaries as of such Recipient’s Separation Date or any business proposed to be conducted by the Partnership or any of its Subsidiaries as evidenced by a written business plan in effect prior to such Recipient’s Separation Date.” Id.

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