IP Law Daily, TRADE SECRETS—Tex. App.: Temporary injunction in insulin case vacated for lack of specificity under Rule 683, (Jun 1, 2026)

By Patricia K. Ruiz, J.D.

The court found that broad references to “confidential” and “trade secret” information fail to provide adequate notice of prohibited conduct.

A Texas appellate court reversed and remanded a temporary injunction in a trade secrets dispute about information relating to a method of insulin delivery, concluding the order failed to comply with Texas Rule of Civil Procedure 683. The court determined the injunction’s sweeping prohibitions—framed in general terms such as “confidential” and “trade secret” information—did not describe the restrained conduct with reasonable particularity. Because the lack of specificity rendered the injunction an abuse of discretion, the court dissolved the order without reaching other appellate issues (Parker v. Well Cell Global LLC, No. 14-25-00909-CV (Tex. App. May 28, 2026)).

Background. The dispute arises from allegations by Well Cell Global LLC and Well Cell Support LLC that Liane Parker misappropriated proprietary information relating to a method of insulin delivery. According to the record, Parker initially engaged with Well Cell after proposing assistance in obtaining a Current Procedural Terminology (CPT) code for a diabetes treatment based on algorithm-driven insulin delivery.

Well Cell contended that Parker used confidential information disclosed during those discussions—including pricing strategies, cost data, and algorithm-related details—to submit CPT code applications on behalf of a former licensee. The plaintiffs asserted claims for breach of nondisclosure and nonsolicitation agreements, as well as theft of trade secrets. The trial court granted a temporary injunction broadly prohibiting Parker from using or disclosing Well Cell’s confidential and proprietary information and from engaging in related competitive conduct. Parker filed an interlocutory appeal challenging that ruling.

Appellate jurisdiction and waiver. As a threshold matter, the court rejected Well Cell’s argument that Parker waived her appellate challenges by addressing only the original injunction order rather than a revised version entered shortly thereafter. The revised order added a trial date but otherwise mirrored the original injunction. The court held that the trial court retained jurisdiction to issue the revised order and that the appellate court could review it. Because the two orders were substantively identical, Parker’s arguments applied equally to both, and no waiver occurred.

Rule 683 and specificity requirements. The court’s analysis centered on the mandatory requirements of Texas Rule of Civil Procedure 683, which governs injunctions. Under the rule, an injunction must (1) state the reasons for issuance, (2) be specific in its terms, and (3) describe in reasonable detail the acts restrained, without incorporating other documents by reference. The court emphasized that these procedural requirements are mandatory, and that noncompliance renders an injunction void and subject to dissolution. An injunction must give clear notice of prohibited conduct so that the restrained party need not rely on inference or risk further litigation to determine its scope.

Deficiencies in the injunction. Applying these principles, the court concluded that the injunction at issue failed to meet Rule 683’s specificity requirement. The order contained multiple provisions prohibiting Parker from using, disclosing, or benefiting from Well Cell’s “confidential,” “proprietary,” or “trade secret” information, often using open-ended language such as “including, but not limited to.”

The court found these terms insufficiently defined. By failing to delineate the precise information at issue, the injunction did not establish clear boundaries for compliance. As a result, Parker would be forced either to interpret the restrictions broadly—potentially limiting lawful activity—or narrowly—risking additional disputes over the scope of the order. The court analogized the injunction to prior decisions invalidating similarly vague orders. It reiterated that generalized descriptions of trade secrets or confidential information, particularly when framed in expansive or non-exhaustive terms, do not provide adequate notice of prohibited conduct. Because six of the eight operative prohibitions in the injunction relied on these undefined categories, the court determined that the defect permeated the order as a whole.

Abuse of discretion. The court held that the temporary injunction violated Rule 683’s requirement of reasonable specificity and therefore constituted an abuse of discretion. It reversed the trial court’s order, dissolved the injunction in full, and remanded the case for further proceedings.

The Case is No. 14-25-00909-CV.

Judge: Boatman, K.

Attorneys: Amir Halevy (Jordan, Lynch & Cancienne PLLC) for Liane Parker. Lema Mousilli (Mousilli Law, PLLC) for Well Cell Global LLC and Well Cell Support LLC.

Companies: Well Cell Global LLC; Well Cell Support LLC

Cases: TradeSecrets TexasNews GCNNews