From Chief Judge Hala Jarbou (W.D. Mich.) Friday in Lothamer Tax Resolution, Inc. v. Kimmel; I think it summarizes the current state of the law well:

Lothamer is a tax services company that hired Kimmel in June 2024 to improve its software. When he was hired, Kimmel signed an Employment Agreement [providing, among other things:]

[Kimmel] covenants and agrees not to make negative comments about [Lothamer] or its officers, directors, current and former employees, or other agents after he … signs this agreement. Such disparagement includes, but is not limited to, making disparaging or discrediting remarks on any internet web site, including but not limited to, internet complaint boards or social media sites, such as FaceBook, Instagram, X (Twitter), TickTock, UTube, Google Reviews, the Bett

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