Has this actually held up? My understanding is that what specific and specialized areas of work on off-time is considered company IP have to be enumerated, and must depend upon availability of unusual proprietary information.
I haven't found any cases in my (admittedly brief) search that actually rule on this, but there's a pretty clear pattern in CA jurisprudence that suggests that a broad application of "related work" is unlikely to be looked upon positively. To me, it's pretty clear that use of trade secrets would be about the only thing that courts are _likely_ to agree upon as out of bounds for personal work.
