 I'm the competition policy director at Public Knowledge, a nonprofit working in the public interest for over 20 years. I want to thank the Federal Trade Commission for your notice of proposed rulemaking to declare non-compete clauses an unfair method of competition. Public Knowledge is particularly concerned about the impact of non-compete clauses on innovation and a competitive marketplace. In addition to harms to workers, non-compete clauses also harm consumers by deterring new business formation, which can lead to diminished competition, innovation, and product quality, as well as higher prices. I am very concerned about dominant firms squashing disruptive innovation to maintain a status quo that supports their dominant position in the market. An employee might come up with a great new idea, but the large firm where she works may not find this disruptive innovation in its own strategic interest. That employee ought to be able to quit and bring her idea to market at another firm or on her own. I also want to take a moment to highlight the importance of rulemaking as a tool for the FTC. Rules are efficient. They save resources by giving clear notice as to what is and isn't allowed. This can cut down on litigation, saving money for the American taxpayer, as well as the businesses regulated by the FTC. Rules can keep up with the pace of innovation. Litigation to clarify the law takes a long time. It took many years of lawsuits for the FTC to finally demonstrate that pay-for-delay settlements can violate the get-to-trust laws. Rulemaking, especially APA rulemaking, can give clarity to the market on a much quicker timeline. Thank you so much for your hard work on this issue.