Non-Signatories May Be Enjoined for Aiding a Non-Compete Breach; Record-Based Territory and Customer/Workforce Loss Support Irreparable Harm

I. Introduction

Puris, LLC. v. CMG Pipelines, Inc. (11th Cir. Sept. 10, 2026) arises from the sale of Murphy Pipeline Contractors, LLC (“Murphy”) to PURIS LLC (“PURIS”) for $55 million. As part of that transaction, Murphy’s founder, Andrew Mayer, signed a non-compete and related restrictive covenants barring competition, solicitation, employee raiding, and support of competing businesses for a defined period and within a defined “Restricted Territory.”

PURIS alleged that Mayer orchestrated a plan—memorialized in his own “THE PLAN” document—to build CMG Pipelines, Inc. (“CMG”), owned by Carmelo Gutierrez, into a direct competitor while Mayer was still Murphy’s president. PURIS sought injunctive relief not only against Mayer (who later stipulated to an injunction) but also against CMG and Gutierrez (the “CMG Parties”), who never signed the non-compete but were alleged to have tortiously interfered with it.

The key appellate issues were narrow: whether the district court abused its discretion in (1) finding irreparable harm to support a preliminary injunction against the CMG Parties, and (2) setting the injunction’s geographic scope using the same 553-location, 50-mile-radius territory applied to Mayer.

II. Summary of the Opinion

The Eleventh Circuit affirmed. It held the district court acted within its discretion in finding irreparable harm based on threats to customers, goodwill, workforce, confidential business opportunities, and competitive position—harms that are difficult to quantify and not readily remedied by money damages. It also upheld the geographic scope, emphasizing the district court’s equitable discretion to “mold its decree to meet the exigencies of the particular case,” and noting the record-based foundation for the 553 locations (including a sworn declaration and Mayer’s own acceptance of that territory for his injunction).

III. Analysis

A. Precedents Cited

  • Gonzalez v. Governor of Ga., 978 F.3d 1266 (11th Cir. 2020)
    Role in the decision: Supplies the governing standard of review (abuse of discretion) and the four-factor preliminary injunction test. The panel uses it to frame the appeal and to emphasize deference to district-court balancing where supported by fact findings.
  • Siegel v. LePore, 234 F.3d 1163 (11th Cir. 2000) (en banc)
    Role in the decision: Reinforces that irreparable injury is the “sine qua non of injunctive relief.” The court uses this to recognize the high importance of the irreparable-harm prong while still concluding the evidentiary record met that standard.
  • Palmer & Cay, Inc. v. Marsh & McLennan Cos., 404 F.3d 1297 (11th Cir. 2005)
    Role in the decision: Confirms that the scope of an injunction is reviewed for abuse of discretion, underscoring that tailoring relief is a discretionary, fact-sensitive exercise.
  • BellSouth Telecomms., Inc. v. MCIMetro Access Transmission Servs., LLC, 425 F.3d 964 (11th Cir. 2005)
    Role in the decision: Provides the key principle that while economic losses alone often do not justify an injunction, “the loss of customers and goodwill is an irreparable injury.” This directly supports the district court’s finding that customer diversion and reputational damage are not easily monetized.
  • Ferrero v. Associated Materials Inc., 923 F.2d 1441 (11th Cir. 1991)
    Role in the decision: Cited through BellSouth as the source of the goodwill/customer-loss irreparable-harm proposition, anchoring the analysis in established circuit law.
  • Yorktown Sys. Grp., Inc. v. Threat Tec LLC, 108 F.4th 1287 (11th Cir. 2024)
    Role in the decision: Modern articulation of why certain competitive injuries are irreparable: broader losses like weakened competitive position and reputational harm are “far more difficult (if not impossible)” to measure. The panel uses Yorktown to bridge from classic goodwill cases to contemporary competitive-dynamics evidence (poached teams, pipeline intel, strategic bidding).
  • Cumulus Media, Inc. v. Clear Channel Communications, Inc., 304 F.3d 1167 (11th Cir. 2002)
    Role in the decision: Appears twice, doing two jobs. First, it recognizes the practical constraints of preliminary-injunction proceedings and the district judge’s role in “delicate balancing.” Second, it supports broad equitable tailoring: an injunction may be “therapeutic as well as protective” and can prohibit conduct that “standing alone, would have been unassailable,” to prevent ongoing benefit from wrongful conduct.
  • Trump v. Int'l Refugee Assistance Project, 582 U.S. 571 (2017)
    Role in the decision: Provides Supreme Court authority for the proposition that crafting preliminary injunctions is an exercise of equitable discretion, including the ability to “mold” relief to the case’s exigencies.
  • Access Now, Inc. v. Sw. Airlines Co., 385 F.3d 1324 (11th Cir. 2004)
    Role in the decision: Used on waiver. The panel rejects PURIS’s argument that CMG waived the geographic-scope issue, because CMG raised it at the October hearing and the district court addressed it.

B. Legal Reasoning

1. Irreparable harm: beyond calculable contract profits

The CMG Parties framed the dispute as a monetary-damages case—lost contracts can be priced, so no injunction. The Eleventh Circuit accepted the general premise that “economic losses alone” are usually insufficient, but it agreed with the district court that the alleged harms were not limited to discrete contract margins.

The court emphasized record evidence of a coordinated scheme: Mayer’s “THE PLAN,” internal communications about allocating work between Murphy and CMG, alleged use of PURIS’s confidential project-development list (“Funnel”), employee raids (at least 27 former Murphy employees), and customer targeting (including a relationship allegedly lost in Nebraska and outreach to the Town of Davie referencing an agreement “similar to” Murphy’s). These facts supported a finding that PURIS faced:

  • Loss of customers and goodwill (BellSouth; Ferrero).
  • Loss of trained workforce and relationship capital (Yorktown’s recognition of difficult-to-measure competitive harm).
  • Misuse of confidential opportunity pipelines, affecting bidding and strategic positioning in ways not easily quantified.
  • Ongoing competitive impairment, because the alleged plan aimed to build a lasting competitor using the very advantages sold to PURIS.

Notably, the injunction’s structure mirrored this reasoning: the district court carved out projects already substantially underway (suggesting those harms were more amenable to damages/accounting) while barring future trenchless work in the territory, where ongoing customer and workforce disruption would be harder to unwind.

2. Geographic scope: equitable tailoring can track the breached covenant where the record supports it

The CMG Parties argued the 553-location map was too broad, contending “Company locations” should mean only PURIS’s sixteen corporate offices. The Eleventh Circuit treated this primarily as a remedial and evidentiary question, not a formalistic contract-interpretation exercise imposed on non-signatories.

The panel’s key move is conceptual: the injunction against CMG was not “blindly” enforcing the non-compete against them; it was stopping alleged tortious interference and preventing continued benefit from the alleged wrongful conduct. Within that posture, the district court could use equitable tools to craft effective relief (Trump; Cumulus Media).

The court found the 553-location territory had a concrete evidentiary basis:

  • A sworn declaration by PURIS’s CEO identifying locations where PURIS operated or maintained customer accounts.
  • Evidence that Mayer had nationwide “general management responsibility” for Murphy’s portfolio and growth.
  • Mayer’s agreement that the same list would define his injunction’s geographic scope.

Importantly, the CMG Parties did not counter with location-by-location evidence showing the list exceeded Mayer’s actual assigned responsibilities or handled accounts; instead, they largely relied on a contract-text argument. Given the record and the district court’s tailoring (including exemptions for existing work and deferral on a New Orleans contract pending public-interest evidence), the Eleventh Circuit concluded the scope fell within permissible discretion (Palmer & Cay; Cumulus Media).

C. Impact

The decision meaningfully strengthens the practical enforceability of non-competes (and related restrictive covenants) against third-party collaborators at the preliminary-injunction stage—at least where plaintiffs can show a strong evidentiary record of coordinated assistance amounting to tortious interference and ongoing competitive harm.

Likely effects include:

  • Expanded preliminary-injunction exposure for non-signatories who recruit restricted employees, exploit confidential bid pipelines, or serve as the vehicle for a restricted seller’s/employee’s competitive re-entry.
  • Broader acceptance of “competitive ecosystem” harms as irreparable—customer relationships, goodwill, workforce cohesion, and confidential opportunity lists—especially when supported by internal planning documents and coordinated communications.
  • Validation of record-based geographic tailoring that can extend beyond formal “office locations” to operational/customer-account footprints when the restricted person’s role is nationwide and the record supports those footprints.

Practically, parties litigating these disputes should expect courts to focus less on abstract definitional fights and more on: (i) what the restricted individual actually managed, (ii) whether the third party is leveraging the restricted individual’s access, and (iii) whether relief can be sensibly carved to avoid undue disruption while stopping forward-looking harm.

IV. Complex Concepts Simplified

  • Preliminary injunction: A temporary court order issued early in a case to preserve the status quo and prevent harm before a final decision. It is based on probabilities and risk balancing, not a final merits determination.
  • Irreparable harm: Harm that cannot be adequately fixed with money later—often because it is hard to measure (e.g., goodwill, customer trust, employee cohesion, competitive position).
  • Tortious interference (with contract): A claim that a third party intentionally and improperly caused or assisted a breach of a contract. Here, it is the theory that allows injunctions against non-signatories—not because they are bound by the contract, but because their own conduct is allegedly wrongful.
  • Restricted Territory: The geographic area in which competitive activity is prohibited by a non-compete. The dispute here was whether that territory was limited to corporate office radii or extended to operational/customer-account locations.
  • “Therapeutic” injunction: Equitable relief that not only blocks specific wrongful acts but also prevents a wrongdoer from continuing to benefit from past misconduct, even if the prohibited conduct might be lawful in isolation (Cumulus Media).

V. Conclusion

Puris, LLC. v. CMG Pipelines, Inc. affirms a pragmatic, evidence-driven approach to preliminary injunctions in restrictive-covenant disputes. The Eleventh Circuit endorsed two central propositions: (1) threats to customer relationships, goodwill, trained workforce, and confidential opportunity pipelines can constitute irreparable harm even when some contract losses are calculable; and (2) when a strong record supports it, a district court may enjoin non-signatories alleged to have tortiously interfered with a non-compete and may adopt a broad, operationally grounded geographic scope to prevent continuing competitive injury—while tailoring carve-outs to reduce unnecessary disruption.