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Lawson Prods., Inc. v. Avnet, Inc - 782 F.2d 1429 (7th Cir. 1986)

Rule:

To be granted an injunction the movant must establish that there is "no adequate remedy at law," a danger of "irreparable harm," and some "likelihood of success on the merits." These are all terms that in the context of preliminary injunctions have acquired their own special meaning. Having gotten past these threshold inquiries the district court must somehow balance the nature and degree of the plaintiff's injury, the likelihood of prevailing at trial, the possible injury to the defendant if the injunction is granted, and the wild card that is the "public interest."

Facts:

This dispute arose out of an alleged scheme by defendant Avnet (a competitor automotive suppliers) to lure customers and sales people away from plaintiff Lawson (an automotive supplier) in a manner that tortiously interfered with the business and contracts of plaintiff Lawson. Plaintiff Lawson filed an action against its competitor , defendant Avnet, for tortious interference with business and contracts and loss of goodwill and confidential information. The trial court determined that it was not entitled to injunction. Lawson appealed.

Issue:

Was the plaintiff entitled to a grant of injunction for tortious interference against defendant?

Answer:

No.

Conclusion:

The trial court did not abuse its discretion by denying Lawson's motion for a preliminary injunction. Pertaining to the tortious interference with business and contracts claims, the district court was within its discretion in denying the preliminary injunction because the past injury indicated a very limited threat of future harm during the pre-trial period and the record was ambivalent as to the merits of the dispute. The trial court also properly concluded that Lawson had not suffered a loss of goodwill or confidential information.

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