When it comes to injunctive relief under the Texas Uniform Trade Secret Act (TUTSA), courts are slowly developing their standards. In First Command Financial Planning, Inc. v. Velez, No. 4:16-cv-01008-0, 2017 WL 2900405 (N.D. Tex. May 8, 2017), the Northern District of Texas stated its standard. For injunctive relief in First Command Financial, the court required a showing of irreparable harm. The Court then cited the San Antonio Court of Appeals case of Hughes v. Age Industries for the proposition that irreparable harm is established by a showing that the “defendant possesses the trade secrets and is in a position to use them.” This is different than the typical standard for irreparable injury, which requires proof that the injured party cannot be adequately compensated by damage or that the damages cannot be measured by any certain pecuniary standard. (Interestingly, Hughes cites the typical standard for irreparable injury but then largely ignores this standard in its analysis.) Thus, Northern District’s standard is more in line with the language of TUTSA, which only states that “actual or threatened misappropriation may be enjoined” and makes no mention of proving irreparable harm.