Nicholas Kreines, David P. Ryan, Liberty Mineral Partners LLC, Nak Resources INC., and CGR Oil and Gas, LLC v. ES3 Minerals, LLC, 15-25-00027-CV

ES3 Minerals, LLC sued former employees Nicholas Kreines and David Ryan, and their new business entities, for alleged misappropriation of trade secrets and breach of noncompetition and nonsolicitation agreements after they left ES3's employment.
On November 26, 2024, the Travis County trial court issued a temporary injunction barring Kreines, Ryan, and Liberty Mineral Partners LLC (LMP) from conducting business with ES3's buyers or soliciting ES3 employees.
Defendants moved to dissolve the injunction, arguing it was vague, lacked adequate reasoning, and was unsupported by an appropriate bond.
The case was transferred to the Texas Business Court, which held a hearing on both sides’ motions and partially modified the injunction to address specificity concerns in paragraph 13, concerning the definition of "Plaintiff’s Buyers."
The court upheld the bases and factual findings for injunctive relief and found the original $25,000 bond sufficient, absent any changed circumstances.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Specificity of Prohibited Acts	Injunction is specific; includes a detailed, confidential list of buyers to prevent circumvention.	Fails Rule 683 specificity; covers unknown subsidiaries/entities, making compliance impossible.	Modified the definition to restrict only listed buyers/entities, plus known subsidiaries; removed ambiguous provisions.
Sufficiency of Reasons for Injunction	Temporary order sets out facts/support for probable right and irreparable harm.	Order failed to articulate detailed factual basis; mainly conclusory.	Found the order sufficiently explained the reasons, meeting Rule 683.
Bond Sufficiency	$25,000 bond is based on evidence; calculated as per law.	Bond is unreasonably low given potential damages.	Held the bond met Rule 684; no changed circumstances to reconsider.
Re-litigation on Motion to Dissolve	Relief should not allow re-litigation; focus is on changed circumstances.	Motion contests original grant, not changed facts.	Reaffirmed that motions to dissolve are not for re-litigation absent new circumstances.

In re Luther, 620 S.W.3d 715 (Tex. 2021) (order must specifically describe prohibited conduct to be enforceable)
Computek Computer & Office Supplies, Inc. v. Walton, 156 S.W.3d 217 (Tex. App.—Dallas 2005) (injunctions must specifically identify prohibited parties or acts)
Tober v. Turner of Texas, Inc., 668 S.W.2d 831 (Tex. App.—Austin 1984) (relitigation on motions to dissolve only on changed circumstances)
Qwest Communs. Corp. v. AT&T Corp., 24 S.W.3d 334 (Tex. 2000) (order failing Rule 683 specificity is void)
El Paso Dev. Co. v. Berryman, 729 S.W.2d 883 (Tex.App.—Corpus Christi 1987) (failure to require sufficient bond does not void injunction)