By James Patton Jr. and Tae Phillips ( July 20, 2017, 12:25 PM EDT) -- We recently published an article entitled, "Nonsolicitation Agreements In The Social Media Age." In the article, we discussed the 21st century problem that employers face when dealing with nonsolicitation agreements in an era dominated by social media such as LinkedIn, Facebook, Twitter and others. As if on cue, on June 26, 2017, the Illinois Appellate Court for the First Judicial District issued a ruling in Bankers Life & Casualty Co. v. American Senior Benefits LLC, et al.[1] affirming a lower court's decision determining that an employee did not violate his nonsolicitation agreement through "passive" LinkedIn activity after beginning work with a new employer....