Mirror-Image Rule Bars Declaratory Counterclaims That Merely Deny Plaintiff's Injunction Elements

In CreateAI Holdings v. Bot Auto TX Inc., the Business Court of Texas granted a Rule 91a motion dismissing declaratory judgment counterclaims that sought only declarations that plaintiff could not prove elements of its injunction claim—imminent irreparable injury and absence of adequate remedy at law. The court held the counterclaims violated the "mirror-image" rule because they presented nothing more than a denial of plaintiff's pending claims and sought no affirmative relief independent of the underlying suit.