Cameron International Corporation v. Jeremy Guillory, 445 S.W.3d 840

This is an interlocutory appeal from a trial court's temporary injunction in an employment case involving a covenant not to compete.
Cameron International Corporation (Delaware corp) sued former employee Jeremy Guillory after he left to join a competitor and allegedly breached confidentiality and noncompetition provisions.
Guillory helped establish Cameron’s Fort Collins, Colorado office; Cameron awarded him restricted stock with a noncompete and other restrictive covenants.
The RSU agreement contained a Delaware governing-law clause and an Electronic Delivery/Acceptance provision for online acceptance of documents.
The trial court enforced Cameron's confidentiality agreement but declined to enforce the RSU noncompete; Cameron sought to enjoin Guillory from competing for one year.
The court ultimately held Delaware law applies to the noncompete, found a probable right to relief, and remanded to grant temporary relief enjoining Guillory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What law governs the RSU noncompete?	Cameron: Delaware law applies per contract's choice-of-law.	Guillory: trial court cannot decide choice-of-law at this stage; waiver issue and premature for temp injunction.	Delaware law applies; contract governs formation/enforceability of the noncompete.
Is Cameron entitled to temporary injunctive relief on the noncompete?	Cameron showed probable right to relief under Delaware law.	Guillory argued no probable right pending merits and potential law conflicts at temp stage.	Yes; trial court erred in denying temporary relief enforcing the noncompete.
Was Guillory's electronic acceptance of the RSU agreement valid and binding?	Guillory accepted online; documents were provided electronically under Delaware law.	Guillory did not carefully read the agreement; questions whether mutual assent existed.	Mutual assent shown; failure to read does not void contract; enforceable noncompete supported.
Does Texas have a greater interest than Delaware in applying the RSU noncompete?	Delaware law should govern as chosen by contract.	Texas has priority due to corporate nexus and local policy around covenants.	Texas has no materially greater interest; Delaware law applies to the noncompete.

DeSantis v. Wackenhut Corp., 793 S.W.2d 670 (Tex. 1990) (recognizes public policy considerations in contract enforcement and choice-of-law issues)
Compaq Computer Corp. v. LaPray, 135 S.W.3d 657 (Tex. 2004) (class-certification and choice-of-law analysis reaffirmed importance of substantive law differences)
Southwest Refining Co. v. Bernal, 22 S.W.3d 425 (Tex. 2000) (prematurity of legal determinations in injunction context requires thorough law review)
In re Olshan Found. Repair Co., LLC, 328 S.W.3d 883 (Tex. 2010) (abuse of discretion when applying improper governing law to injunctive relief)
In re Prudential Ins. Co., 148 S.W.3d 124 (Tex. 2000) (statements on due consideration of law in injunction context and standards)