Chicago Illinois Jury Instruction — 6.1 Raiding Key Employees is a legal instruction provided to the jury in cases related to the raiding of key employees by a business in Chicago, Illinois. This instruction focuses on the legal principles that the jury must consider when determining liability and damages in such cases. Here is a detailed description of the instruction: 1. Definition and Purpose: The Chicago Illinois Jury Instruction — 6.1 Raiding Key Employees provides guidance to the jury when a business is accused of raiding or soliciting key employees from another business. The purpose of this instruction is to explain the legal elements necessary to establish liability for such actions and to help determine appropriate damages if the defendant is found liable. 2. Elements of Raiding Key Employees: The instruction outlines the essential elements that the plaintiff must prove to establish a raiding key employees claim. These elements typically include: a. The existence of a valid employment relationship between the plaintiff (prior employer) and the alleged key employees. b. The defendant's knowledge of the employment relationship. c. The defendant's intentional and unjustified interference with the employment relationship. d. The resulting harm or damage suffered by the plaintiff. 3. Consideration of Conduct: The instruction also instructs the jury to consider the conduct of both the plaintiff and the defendant. Relevant factors include: a. The nature and duration of the employment relationship. b. The defendant's intent or motive behind the recruitment or solicitation of key employees. c. Whether the actions taken by the defendant were lawful or involved improper means. d. Any harm caused to the plaintiff's business as a result of the raiding. 4. Damages: Furthermore, the instruction offers guidance on the types of damages the jury may consider when determining the appropriate compensation for the plaintiff. These damages can include: a. Actual damages: Financial losses suffered by the plaintiff as a direct result of the raiding key employees. b. Lost profits: Loss of revenue and business opportunities resulting from the defendant's actions. c. Punitive damages: Extra compensation awarded to punish the defendant for willful misconduct or egregious behavior. d. Equitable relief: In certain cases, the jury may consider injunctions or other appropriate remedies to prevent future raiding or solicitation practices. Types of Chicago Illinois Jury Instruction — 6.1 Raiding Key Employees may include: 1. Chicago Illinois Jury Instruction — 6.1A Raiding Key Employee— - General Instruction 2. Chicago Illinois Jury Instruction — 6.1B Raiding Key Employee— - Measurement of Damages 3. Chicago Illinois Jury Instruction — 6.1C Raiding Key Employee— - Special Considerations These variations of the instruction address specific aspects related to raiding key employees, such as special considerations in calculating damages or additional factors to be considered in determining liability. In conclusion, the Chicago Illinois Jury Instruction — 6.1 Raiding Key Employees provides comprehensive guidance to the jury when evaluating claims involving the raiding of key employees in Chicago, Illinois. By outlining the elements of the claim, considering relevant conduct, and elucidating the available damages, this instruction helps ensure a fair and just outcome in cases involving alleged employee poaching.