Transunion Risk and Alternative Data Solutions, Inc. v. Surya Challa, 676 F. App'x 822

TRADS (TransUnion Risk and Alternative Data Solutions) enforces a noncompetition agreement against former employee Surya Challa after he left to work for IDI (a competitor) instead of Bloomberg.
Challa had executed a 2-year noncompete with TLO (pre-acquisition) and later a 1-year TRADS noncompete that explicitly named Interactive (an IDI subsidiary) as a competitor.
At TRADS Challa worked on TLOxp (data fusion product); at IDI he worked on cloud infrastructure for idiCORE/IDI Basic — a different role though interacting with the data team.
The district court found TRADS likely to succeed on the breach-of-noncompete claim (triggering Florida’s presumption of irreparable harm) but credited Challa’s testimony that he had not and would not disclose TRADS’s proprietary information and that his IDI role made use of TRADS’s confidential information unlikely.
The district court denied a preliminary injunction because it concluded TRADS failed to prove irreparable injury; TRADS appealed arguing the court applied the wrong legal standard and made clearly erroneous factual findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether TRADS suffers irreparable harm such that a preliminary injunction is warranted	Mere employment of former employee by a competitor creates irreparable harm; presumption of irreparable injury should be dispositive	The presumption is rebuttable; harm must be actual and imminent, and Challa rebutted the presumption with credible testimony and facts	Court held presumption is rebuttable; district court did not err in finding no irreparable harm because harm was speculative
Burden allocation and standard for irreparable harm after finding enforceable covenant	Enforceability of covenant should automatically establish irreparable harm for injunction purposes	Enforceability satisfies likelihood-of-success prong but does not eliminate requirement that harm be actual and imminent; employee bears burden to rebut presumption	Court held enforceability and irreparable-harm analyses are distinct; employee successfully rebutted presumption

Proudfoot Consulting Co. v. Gordon, 576 F.3d 1223 (11th Cir.) (discusses enforceability of noncompetition agreements and presumption of irreparable harm)
Jysk Bed’N Linen v. Dutta-Roy, 810 F.3d 767 (11th Cir.) (standard of review for preliminary injunctions)
Ne. Fla. Chapter of Ass’n of Gen. Contractors of Am. v. City of Jacksonville, 896 F.2d 1283 (11th Cir.) (irreparable injury must be actual and imminent)
Siegel v. LePore, 234 F.3d 1163 (11th Cir.) (speculative future harm is insufficient for irreparable injury)
Lincoln v. Bd. of Regents of Univ. Sys. of Ga., 697 F.2d 928 (11th Cir.) (deference to district court credibility findings)
Weinstein v. Bradford, 423 U.S. 147 (U.S. Supreme Court) (exception to mootness where action too short to litigate and likely to recur)
Vencor, Inc. v. Webb, 33 F.3d 840 (7th Cir.) (mootness exception where employee works in specialized industry and future plans are unclear)
Capraro v. Lanier Business Products, Inc., 466 So.2d 212 (Fla.) (discusses presumption of irreparable harm from covenant breach)
Environmental Services, Inc. v. Carter, 9 So.3d 1258 (Fla. Dist. Ct. App.) (addresses burden to demonstrate absence of irreparable injury)