In my previous posts, I have discussed the varying standards for injunctive relief under the Texas Uniform Trade Secret Act (TUTSA). Some courts have required showings of irreparable harm. The Southern District of Texas, however, does not. In Orion Marine Construction, Inc. v. Coyle, No. 4:17-CV-00522, 2017 WL4875596 (S.D. Tex. October 26, 2017), the Southern District of Texas evaluated plaintiff’s proposal to modify the court’s preliminary injunction order to prohibit plaintiff’s competitor from bidding on certain projects that plaintiff’s former employee worked on while with plaintiff. Citing TUTSA’s standard that “[a]ctual or threatened misappropriation may be enjoined . . . ,” the Court granted plaintiff’s request, noting that the testimony had established that the former employee had misappropriated confidential information and remained in possession of it. Such a standard is similar to the one announced by the Northern District of Texas earlier in 2017. However, unlike other courts, the Southern District made no mention of having to prove irreparable harm.