In Doyle v. Nutrilawn U.S., Inc., 2010 U.S. Dist. LEXIS 48613 (W.D. Wash. May 17, 2010), a Washington federal court concluded that language in a noncompete clause making it applicable “following the termination of this Agreement for any reason whatsoever” applied upon the agreement’s expiration. The franchisee argued that the covenant only applied if the agreement was terminated, and that termination and expiration should be treated differently. After reviewing “the franchise agreement as a whole” and “giving its terms their ordinary meaning,” the court concluded that the noncompete covenant would apply, but refused to enforce it because the franchisor failed to present sufficient evidence that the covenant was violated.