Atlas Copco Compressors LLC v. Baker
5:25-cv-00874
| W.D. Okla. | Aug 14, 2025Background
- Atlas Copco Compressors, LLC sued former employees (Eric Baker, Blake Houck, Joseph Houck) and Air Capital Equipment, Inc., alleging misappropriation of trade secrets and breach of confidentiality agreements.
- Plaintiff sought an emergency temporary restraining order (TRO) to prevent the alleged use or disclosure of confidential information and trade secrets.
- Defendants had not yet appeared or responded in this case, but the court has authority to rule on TRO requests without notice under Rule 65(b).
- Plaintiff claimed imminent, irreparable harm to its goodwill and customer relationships if the TRO was not granted.
- The court evaluated the request under the four factors for injunctions: likelihood of success, irreparable harm, balance of harms, and public interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Irreparable Harm | Atlas Copco argued imminent, unquantifiable harm to goodwill and customer relations from trade secret misuse. | Not presented (Defendants had not appeared). | Plaintiff failed to show irreparable harm: alleged injuries were speculative, and resolved incidents did not show imminent harm. |
| Likelihood of Success | Atlas Copco alleged Defendants misappropriated trade secrets and breached contracts, supporting a TRO. | Not presented. | Plaintiff's arguments were speculative, based largely on "information and belief" without specific evidence regarding use or disclosure. |
| Adequacy of Legal Remedy | Claimed damages to intangible assets (goodwill) could not be remedied by money damages. | Not presented. | Plaintiff offered no evidence damages would be inadequate; failed to show traditional remedies insufficient. |
| Balance of Harms/Public Interest | Claimed risk to business outweighed any hardship to Defendants and TRO would not harm public interest. | Not presented. | Court did not address these, as failure on first two (irreparable harm, likelihood of success) was dispositive. |
Key Cases Cited
- Dine Citizens Against Ruining Envir. v. Jewell, 839 F.3d 1276 (10th Cir. 2016) (sets standards for TRO/preliminary injunction, requiring clear showing on four factors)
- Davis v. Mineta, 302 F.3d 1104 (10th Cir. 2002) (articulates preliminary injunction factors)
- GTE Corp. v. Williams, 731 F.2d 676 (10th Cir. 1984) (TROs are drastic relief, exception not the rule)
- First W. Cap. Mgmt. Co. v. Malamed, 874 F.3d 1136 (10th Cir. 2017) (irreparable harm is essential for preliminary relief)
- Salt Lake Tribune Pub. Co., LLC v. AT&T Corp., 320 F.3d 1081 (10th Cir. 2003) (likelihood of success standard for injunctions)
- Koerpel v. Heckler, 797 F.2d 858 (10th Cir. 1986) (movant must present more than speculation for likelihood of success)
- RoDa Drilling Co. v. Siegal, 552 F.3d 1203 (10th Cir. 2009) (speculative injury insufficient for irreparable harm)