Frank D. Gillitzer Elec. Co., Ltd. v. Andersen, No. 2009AP939, 2010 WL 173895 (Ct. App., Jan. 10, 2010). Former Gillitzer employees had signed an Educational And Non-Competition Agreement, allowed them to particpate in an apprenticeship program. The agreement contained provisions for repayment of training costs under certain circumstances and restrictive covenant provisions. Gillitzer conceded the latter were unenforceable. The employees argued that the training reimbursement provisions were subject to Wis. Stat., sec. 103.465 and could not be enforced because they were intertwined with the restrictive covenants and therefore not divisible under the Streiff case. Gillitzer argued that the Star Direct case created a new test for divisibility, pursuant to which the training reimbursement program was neither intertwined nor textually linked. Recognizing that if the training reimbursement provision were standing alone, it would not fall within Wis. Stat. 103.465, and without deciding whether Star Direct created a new test, the Court of Appeals held that training program was divisible from the restrictive covenants under either Streiff or Star Direct. The training reimbursement and non-compete provisions were not dependent on each other for their meanings. Although both were requirements of accepting the apprenticeship money, they imposed separate requirements. If either provision were stricken, the other would still be independently understood. Additionally, unlike in Streiff, the two provisions did not share identical factual triggers. Unlike in Streiff, there was no cross-referencing, textual linkage and shared content within the paragraphs.