Injunction, Modified

Computer Sciences Corp. v. Tata Consultancy Services reformed a trade-secret injunction to better match the substantial damages that were also awarded. In particular, the Fifth Circuit held that where a plaintiff has already received unjust enrichment damages—calculated here as avoided development costs—the injunction cannot also bar the defendant’s future use of the technology it built during the misappropriation

The Court recognized two, related principles: (1) unjust enrichment damages are designed to strip the defendant of the benefit accrued from misappropriation and put the defendant in the position it would have occupied had it incurred those development costs lawfully; (2) an injunction cannot then deprive the defendant of the very fruits it has now effectively paid for, because that would be duplicative and punitive.

In other words, once the defendant has been compelled to pay the avoided costs, equity does not also forbid use of the resulting post-misappropriation implementation. Equity does, however, continue to forbid any possession, access, or use of the trade secrets themselves.

The Cout also required the injunction to be conformed to Federal Rule of Civil Procedure 65(d)(2), to clarify that the scope of the specific parties bound by the injunction was consistent with the terms of that rule. No. 24-10749; Nov. 21, 2025.