Accellix, Inc. v. Aguilera-Sandoval
8:25-cv-00440
M.D. Fla.Apr 8, 2025Background
- Accellix, Inc. is a medical equipment manufacturer specializing in automated cell phenotyping, marketing its products internationally.
- Defendant, Christian Aguilera-Sandoval, was employed as Associate Director of Scientific Affairs and had access to Accellix’s confidential business information and trade secrets.
- Defendant signed a Proprietary Information and Invention Assignment Agreement restricting competition in similar business areas during employment and for 12 months after termination.
- After resigning, Defendant made LinkedIn posts offering competing consulting services and products, and operated a similar consulting company (CRBECH Investments, Inc.), allegedly in breach of the non-compete agreement.
- Accellix sought a preliminary injunction to enforce the agreement, claiming breach of contract and breach of duty of loyalty.
- The court granted a preliminary injunction, prohibiting Aguilera-Sandoval from competing in specified ways for one year, contingent on a $500,000 bond posted by Accellix.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Breach of Non-Compete Agreement | Defendant directly competed by offering similar products/services post-employment | His activities did not directly compete; posts weren't covered by agreement | Likely breach; Plaintiff showed likelihood of success |
| Validity/Enforceability of Restrictive Covenant | Agreement protects legitimate business interests; restrictions reasonable | Geographic and product restrictions overbroad; not reasonably necessary | Covenant is reasonable, justified, and enforceable |
| Irreparable Injury | Loss of goodwill and customer relationships is irreparable harm | No actual customer loss established; no irreparable harm shown | Threat of loss sufficient for irreparable harm |
| Balance of Harms/Public Interest | Injunction necessary to protect confidential info and enforce contracts | Injunction unduly burdens Defendant's ability to work | Balance favors Plaintiff; public interest in contract enforcement |
Key Cases Cited
- Schiavo ex rel. Schindler v. Schiavo, 403 F.3d 1223 (11th Cir. 2005) (sets standard for preliminary injunctions in the Eleventh Circuit)
- Wreal, LLC v. Amazon.com, Inc., 840 F.3d 1244 (11th Cir. 2016) (movant must clearly establish all elements for injunctive relief)
- Ferrero v. Assoc. Materials, Inc., 923 F.2d 1441 (11th Cir. 1991) (loss of goodwill and customers may constitute irreparable harm)
- Proudfoot Consulting Co. v. Gordon, 576 F.3d 1223 (11th Cir. 2009) (upholds nationwide non-compete restrictions as reasonable when business is national or international)
- AutoNation, Inc. v. O'Brien, 347 F. Supp. 2d 1299 (S.D. Fla. 2004) (enforces non-compete covering all areas where employer operates)
