OPINION AND ORDER Plaintiff International Business Machines Corporation (“IBM” or “Plaintiff”) moves pursuant to Fed. R. Civ. P. 65 for a preliminary injunction, seeking to enjoin Defendant Rodrigo Kede De Freitas Lima (“Mr. Lima” or “Defendant”) from, inter alia, commencing employment at Microsoft Corporation (“Microsoft”) as Corporate Vice President for Latin America. For the reasons set forth below, Plaintiff’s application for a preliminary injunction is GRANTED. BACKGROUND On June 15, 2020, IBM filed its Complaint alleging claims for breach of contract, misappropriation of trade secrets, and declaratory judgment concerning rescission of Defendant’s equity award. (Doc. 1, “Compl.”). On June 18, 2020, Plaintiff moved by way of Order to Show Cause for a preliminary injunction and a temporary restraining order. (Docs. 12-15). Defendant opposed the application. (Docs. 16-18). On June 19, 2020, after the Court heard oral argument concerning the temporary restraining order, I signed an Order to Show Cause as to why a preliminary injunction should not be ordered to bar Mr. Lima from, inter alia, working for Microsoft; and granted a temporary restraining order which prohibited Mr. Lima from commencing employment at Microsoft in violation of his Non-Competition Agreement with IBM, soliciting certain customers of IBM, and retaining, using, or disclosing IBM confidential or proprietary information. (Doc. 12, “TRO”). The TRO was extended three times for good cause shown and until the hearing on IBM’s motion for a preliminary injunction concluded, and to provide the Court with an opportunity to review the voluminous record and issue this Opinion and Order. The parties conducted expedited discovery and submitted pre-hearing briefs and declarations on July 13, 2020. (Docs. 27, 29-33, 36). The Court conducted an evidentiary hearing on the motion for a preliminary injunction and heard testimony over the course of three days.1 Thereafter, the parties submitted offers of proof, post-hearing briefs, declarations, and opposition thereto. (Docs. 58-64, 66-68, 71). A summary of the significant evidence adduced during the preliminary injunction motion and hearing process is set forth below. I. The Parties’ Proof Mr. Lima worked at IBM for approximately 25 years. (Tr. at 378:11-25, 379:1-9, 380:3-5, 385:14-16, 390:16-19; Doc. 17, “Lima Decl.,” 2). In 2010, Mr. Lima took over IBM’s Global Technology Service (“GTS”) organization in Brazil, and then became General Manager of IBM in Brazil until 2015. (Tr. at 379:6-9). Mr. Lima left IBM for approximately one year, and, in January 2016, returned to IBM in Brazil as General Manager for Latin America. (Tr. at 380:8-16). In July 2017, Mr. Lima accepted the role of General Manager, GTS, North America (specifically, the United States and Canada). (Tr. at 385:14-21; Lima Decl. 31). In January 2020, Mr. Lima became General Manager of Integrated Accounts, until his resignation on May 18, 2020. (Lima Decl. 33). From 2016 until his resignation in May 2020, Mr. Lima was a member of IBM’s Performance Team. Mr. Lima was also a member of IBM’s Acceleration Team. (Lima Decl.
16, 18). Mr. Lima was a “Band A” executive, which IBM describes as the highest rank below the Senior Vice President level. (Compl. 5; Doc. 49, “Answer,” 5). As relevant to IBM’s instant application, on December 3, 2019, Mr. Lima executed a Non-Competition Agreement in connection with his employment as a Senior Executive at IBM. (Answer
