Business Court Grants Partial Injunction on Non-Compete, Applies Blue Pencil Doctrine to Overbroad Covenant

In Galderma Laboratories v. Brenner, the Texas Business Court's Eighth Division granted in part a temporary injunction enforcing a non-compete agreement against a former executive, but reformed the covenant's scope under the blue pencil doctrine after finding certain service restrictions overbroad. The court denied injunctive relief on customer non-solicit, worker non-solicit, confidentiality, and TUTSA claims, finding Galderma failed to meet its burden on probable success or irreparable harm.