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Dallas, Texas  ·  Complex Commercial Litigation

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15-25-00027-CV December 04, 2025

Business Court Modification of Temporary Injunction Fails Rule 684 Bond Requirement in Non-Compete Dispute

The Fifteenth Court of Appeals reversed in part a Business Court order modifying a temporary injunction against former ES3 Minerals employees and their competing venture, holding that the injunction bond failed to adequately protect appellants' interests under Rule 684 and that the order lacked adequate specificity regarding enjoined subsidiaries. The court also held that challenges to portions of the injunction imposed by the original district court—but not reviewed or reimposed by the Business Court—were not properly before it on appeal.

Affirmed in Part & Reversed in Part Mem. Op. Portrait of Hon. April Farris Justice Farris Opinion PDF ↓