DAE think agency non-competes are mostly scare tactics?

I read a case from the Northern District of Illinois last week where a judge threw out a two year non-compete because the agency couldn't show any real trade secrets, just client lists that were public on the company website. It got me thinking about how many agencies use these clauses to scare junior staff into staying, even when they know the agreement would never hold up in court. A recruiter in Austin showed me three contracts last month that all had the same boilerplate language copied from a template, and none of them mentioned any actual proprietary info. So my take is this: if you are a mid-level creative and your agency is threatening you with a non-compete, talk to a lawyer before you panic, because most of these things are paper tigers. Has anyone here actually seen one enforced, or is it all just scary letters?