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The article says: "Non-compete agreements probably prohibit Hamburg working on the kind of software at Microsoft that helped turn Adobe into the company it is today."

Non-compete agreements aren't enforceable in California.

http://en.wikipedia.org/wiki/Non-compete_clause#Enforceability_in_the_State_of_California

"Unlike the situation in other states, non-compete agreements are illegal in California and against public policy. (California Business and Professions Code Section 16600)."

   -Don