Insight Direct USA, Inc. v. Kelleher, 1:17-cv-00252

Insight Direct USA, Inc. sought a preliminary injunction against Christopher Kelleher in the Western District of Texas (1:17-CV-252-RP).
The court issued a Temporary Restraining Order on April 5, 2017, enjoining Kelleher from violating certain terms pending a preliminary injunction hearing.
On April 11, 2017, the court set an expedited discovery and hearing schedule, with a preliminary injunction hearing planned for April 28, 2017.
Rule 65(b)(2) limits a TRO to 14 days unless extended for good cause or with consent, and does not define ‘good cause.’
The grounds for the TRO, and the parties’ joint proposal for an expedited schedule, suggested continued need for relief beyond 14 days.
The court extended the TRO, stating it would remain in effect until May 3, 2017 at 11:59 p.m. or until the final decision on the preliminary injunction, whichever comes first.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether good cause existed to extend the TRO beyond 14 days	Kelleher's grounds for the TRO continued to exist.	Not stated in the opinion.	Yes; good cause existed to extend the TRO.
Whether the TRO extension complied with the 28-day outer limit for TRO duration	Extension compatibility with the 28-day limit supported by expedited schedule.	Not stated in the opinion.	TRO extended to May 3, 2017 (or final decision), up to 28 days total.

Flying Cross Check, L.L.C. v. Cent Hockey League, Inc., 153 F.Supp.2d 1253 (D. Kan. 2011) (grounds for TRO extension may establish good cause)
U.S. D.I.D. Corp. v. Windstream Comms., Inc., 775 F.3d 128 (2d Cir. 2014) (TRO duration limits and extensions under Rule 65(b)(2))
SEC v. Unifund Sal, 910 F.2d 1028 (2d Cir. 1990) (court may continue a TRO while reserving decision on PI)
Hellenic Duty Free Shops S.A. v. H-D Mich., LLC, 694 F.3d 827 (7th Cir. 2012) (28-day TRO outer limit and extensions require consent for longer durations)