Salomon & Ludwin, LLC v. Jeremiah Winters

PUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 24-1728
SALOMON & LUDWIN, LLC,
Plaintiff – Appellee,
v.
JEREMIAH WINTERS; CATHERINE ATWOOD; JENNIFER THOMPSON;
ABBEY SORENSEN; ALBERO ADVISORS, LLC, d/b/a Founders Grove Wealth
Partners, LLC,
Defendants – Appellants.
Appeal from the United States District Court for the Eastern District of Virginia, at
Richmond. Henry E. Hudson, Senior District Judge. (3:24-cv-00389-HEH)
Argued: May 9, 2025 Decided: August 12, 2025
Before QUATTLEBAUM, RUSHING and HEYTENS, Circuit Judges.
Affirmed in part and vacated in part by published opinion. Judge Quattlebaum wrote the
opinion, in which Judge Rushing and Judge Heytens joined.
ARGUED: Henry Willett, III, CHRISTIAN & BARTON, LLP, Richmond, Virginia, for
Appellants. Paul Anthony Werner, III, SHEPPARD MULLIN RICHTER & HAMPTON,
LLP, Washington, D.C., for Appellee. ON BRIEF: Denise Giraudo, Imad Matini, Hannah
Wigger, Christopher Bauer, Tifenn Drouaud, SHEPPARD MULLIN RICHTER &
HAMPTON LLP, Washington, D.C., for Appellee.

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QUATTLEBAUM, Circuit Judge:
Several employees of a financial services firm left to start a competing firm and then
began contacting their former clients. But they had signed employment agreements with
the former employer prohibiting the solicitation of clients and use of confidential client
information. The former employees, however, thought they had an out. Their old firm, like
many in the financial services field, had agreed to an industry-wide protocol under which
their employees could join another firm and contact former clients if they followed certain
procedures. Unfortunately for the former employees, their employment agreements also
said their contractual non-solicitation and confidentiality obligations, not the protocol,
controlled.
The former firm sued its former employees and their newly created firm, and moved
for a preliminary injunction barring any contact between defendants and their former
clients and any use of the old firm’s confidential information. The district court granted the
injunction, finding that the former employer showed a strong likelihood of success on the
merits of its violation of trade secrets claims against all defendants whether the
employment agreements or the protocol controlled. According to the district court, even
under the protocol, defendants were not permitted to “raid” the former firm. For the reasons
set forth below, we agree the old firm is likely to succeed on the merits of those claims
against the former employees, but only under the employment agreements. The new firm
itself, however, is not a party to those agreements, nor did it raid the former firm as that
term is ordinarily understood. So, the district court erred in issuing an injunction against
the new firm. We therefore affirm in part and vacate in part.

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I.
Formed in 2009, Salomon & Ludwin, LLC is a wealth management firm based in
Richmond, Virginia. Salomon hired Jeremiah Winters, Catherine Atwood, Jennifer
Thompson and Abbey Sorensen between 2009 and 2017. Winters and Atwood were
financial advisors, and Thompson and Sorensen were operational professionals.
All of Salomon’s employees generally have access to proprietary client information.
Salomon takes several steps to protect this proprietary information. Most significantly, it
requires financial advisors, like Winters and Atwood, to sign a Financial Services
Professional Employment Agreement. And it requires operational professionals, like
Thompson and Sorensen, to sign an Administrative Professional Employment Agreement.
Since the relevant provisions of both agreements are largely identical, we will use the term
“Agreement” to refer to both. Winters, Atwood, Thompson and Sorensen signed these
Agreements in March 2022.
The Agreements contain a number of provisions that protect Salomon. They provide
that Salomon has all rights to current and future clients of the firm as well as revenue
generated from those clients. The Agreements state that client information is a trade secret.
And they prohibit an employee from soliciting Salomon’s clients for two years after the
end of their employment.
On top of that, attached to each Agreement is a confidentiality agreement, which
prohibits an employee from disclosing Salomon’s trade secrets and client information. The
confidentiality agreement also states that Salomon will suffer irreparable harm in the event
of a breach of confidentiality.

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Complicating these provisions, Salomon signed on to an industry-wide document
called the Protocol for Broker Recruiting. The Protocol is a separate voluntary agreement
among firms in the financial services industry that allows a departing financial advisor,
with written notice, to take certain client information with them when leaving one member-
firm to join another member-firm. It provides:
The principal goal of the following protocol is to further the clients’ interests
of privacy and freedom of choice in connection with the movement of their
Registered Representatives (“RRs”) between firms. If departing RRs and
their new firm follow this protocol, neither the departing RR nor the firm that
he or she joins would have any monetary or other liability to the firm that the
RR left by reason of the RR taking the information identified below or the
solicitation of the clients serviced by the RR at his or her prior firm, provided,
however, that this protocol does not bar or otherwise affect the ability of the
prior firm to bring an action against the new firm for “raiding.” The
signatories to this protocol agree to implement and adhere to it in good faith.
J.A. 250. So long as a financial advisor complies, the Protocol shields both the departing
financial advisor and the new member-firm from liability.
Complicating things a bit more, the Agreements address the Protocol, stating that:
The parties to this agreement acknowledge that [Salomon] is not part of or
subject to Broker Protocol. In the event [Salomon] elects to join the Broker
Protocol, the parties further agree that this agreement shall take precedence
over and shall apply, regardless of the terms of the Protocol for Broker
Recruiting and that this agreement shall apply and control in the event that
any term of this agreement conflicts with any term of the Protocol for Broker
Recruiting.
J.A. 56, 71, 85, 99 (capitalization altered). But this provision appears outdated because
Salomon joined the Protocol in March 2018—long before Winters, Atwood, Thompson
and Sorensen executed these Agreements.

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While still employed at Salomon in the spring of 2024, Winters, Atwood, Thompson
and Sorensen decided to leave Salomon and found their own firm. They set up a business
known as Albero Advisors, LLC. A month and a half later, they resigned from Salomon.
That same day, Albero Advisors joined the Protocol. According to Winters and Atwood,
their resignation letters listed the clients they served at Salomon, including client names,
addresses, phone numbers, email addresses and account titles, all in accordance with the
Protocol. At the same time, the departing employees began contacting Salomon’s clients,
informing them of their new endeavor and stating that they would be in touch. The result—
Salomon lost over four hundred accounts representing hundreds of millions of dollars in
client assets.
Salomon quickly sued the former employees, Winters, Atwood, Thompson,
Sorensen and Albero Advisors. And because Albero Advisors had at some point changed
its name to Founders Grove Wealth Partners, LLC, Salomon sued Founders Grove too.
Salomon alleged (1) violations of the Defend Trade Secrets Act under 18 U.S.C. §
1836(b)(1) against all defendants; (2) violations of the Virginia Uniform Trade Secrets Act
under Va. Code § 59.1-336 et seq. against all defendants; (3) tortious interference with
business relations against all defendants; (4) breach of the duty of loyalty against former
employees; and (5) breach of contract against former employees. Salomon also sought a
declaratory judgment pursuant to 28 U.S.C. § 2201 against all defendants. Simultaneously,
Salomon filed an emergency motion for a temporary restraining order, which the district
court granted.

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Salomon then moved for and obtained a preliminary injunction. As to the likelihood
of success on the merits of Salomon’s claims, the district court found no dispute that
Salomon’s client information likely constituted a trade secret and that defendants obtained
that information through their relationship with Salomon.1 Thus, in the absence of the
Protocol, Salomon had shown a strong likelihood of success on the merits.2 But because
both Salomon and Founders Grove were members of the Protocol—which permits
financial advisors to leave their firms with certain information—the district court
determined that it had to consider the impact of the Protocol. However, the district court
held that even if the Protocol controlled over the Agreements, the raiding exception to the
Protocol applied because defendants had likely raided Salomon. Then, the district court
found Salomon established it was likely to suffer irreparable harm, relying on Salomon’s
evidence regarding its business losses and Fourth Circuit precedent that holds the loss of
goodwill, customers and the ability to attract new customers may entitle a party to
injunctive relief. The court then found the balance of equities and public interest cut in
1 The district only analyzed the trade secret claims. But that limited analysis does
not affect the outcome of this appeal because “[f]inding a likelihood of success on only one
claim is sufficient to justify injunctive relief.” Variable Annuity Life Ins. Co. v. Coreth, 535
F. Supp. 3d 488, 494 n.3 (E.D. Va. 2021) (internal quotation marks and citation omitted).
See also Nabisco Brands, Inc. v. Conusa Corp., No. 89-2704, 1989 WL 152508 at *2 (4th
Cir. Dec. 1, 1989) (stating that “showing of entitlement to preliminary injunctive relief
with respect to any . . . claims . . . obviates the necessity to consider any other”).
2 Relying on substantial similarities between the federal and state trade secret
statutes, the district court considered them together. And for purposes of this appeal, we do
the same.

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favor of granting injunctive relief. Thus, the district court granted Salomon a preliminary
injunction, and defendants timely appealed.3
II.
“[P]reliminary injunctions are extraordinary remedies involving the exercise of very
far-reaching power to be granted only sparingly and in limited circumstances . . . .” Direx
Israel, Ltd. v. Breakthrough Med. Corp., 952 F.2d 802, 816 (4th Cir. 1991) (internal
quotation marks omitted). To prevail, a party must show: (1) likelihood of success on the
merits; (2) likelihood of irreparable harm absent preliminary relief; (3) equity favors
granting preliminary relief; and (4) preliminary relief is in the public interest. See Winter
v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008).
We review a district court’s grant or denial of a preliminary injunction for abuse of
discretion. See Direx, 952 F.2d at 814. Although we may not reweigh evidence the district
court considered, a clear error in factual findings or a mistake of law merits reversal. See
Mountain Valley Pipeline, LLC v. 6.56 Acres of Land, Owned by Sandra Townes Powell,
915 F.3d 197, 213 (4th Cir. 2019). We review de novo whether there has been a mistake
of law. See Nelson-Salabes, Inc. v. Morningside Dev., LLC, 284 F.3d 505, 512 (4th Cir.
2002).
Defendants argue that the court erred in determining that if the Protocol controlled,
defendants’ conduct constituted raiding. We agree the court incorrectly interpreted raiding.
But as to the former employees, we nevertheless affirm because the Agreements controlled
3 This court has jurisdiction over this interlocutory appeal under 28 U.S.C.
§ 1292(a)(1) and 28 U.S.C. § 1331.

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over the Protocol and prohibited their conduct. As to Founders Grove, we vacate the
injunction because it was not a party to the Agreements.
A. The Protocol
In determining that Salomon was likely to succeed in showing defendants’ conduct
constituted raiding under the Protocol, the district court first had to determine what that
term meant. Without a definition in the Protocol or established case law, it relied on the
parties’ competing experts to define raiding. It ultimately settled on a definition of a severe
economic impact on the prior firm resulting from a raider’s “malice/predation and/or
improper means.” Salomon & Ludwin, LLC v. Winters, 741 F. Supp. 3d 398, 405–06 (E.D.
Va. 2024) (internal quotation marks omitted). The court identified severe economic impact
as the loss of 40% production but indicated this was a guideline, not a requirement. Id. at
406. And it found that defendants’ efforts to start a competing firm while still employed
by Salomon—combined with the resulting loss of 40% of Salomon’s total employees, 50%
of Salomon’s financial advising team and approximately 30% of Salomon’s business,
including over 400 accounts that amounted to upwards of $300,000,000 in assets—
constituted raiding. Id.
Defendants’ appeal requires us to review the district court’s interpretation of
raiding, which is a legal question. See Scarborough v. Ridgeway, 726 F.2d 132, 135 (4th
Cir. 1984) (the “interpretation of a written contract is a question of law . . . .”). We find the
district court’s definition is inconsistent with the text of the Protocol, the ordinary meaning
of the term “raid” and the industry-specific meaning as all three suggest raiding involves a
separate firm targeting employees of another firm.

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1. The Text
First, the text. The Protocol says that it “does not bar or otherwise affect the ability
of the prior firm to bring an action against the new firm for ‘raiding.’” J.A. 250. That
language applies only to an action against a firm—not individuals. Also, reading this
sentence in context with the Protocol as a whole supports this interpretation. See A NTONIN
SCALIA & BRYAN GARNER , READING L AW: T HE INTERPRETATION OF L EGAL TEXTS 167
(2012) (“A legal instrument typically contains many interrelated parts that make up the
whole. The entirety of the document thus provides the context for each of its parts.”).
Compliance with the Protocol shields a departing financial advisor and the “firm that he or
she joins” from liability. J.A. 250. The use of the term “joins” refers to a financial advisor
leaving one firm to go work at a competing firm, not all instances of a financial advisor
leaving. Thus, the Protocol contemplates liability when an outside firm preys upon another
firm, not when individuals leave a firm.
History helps illustrate this distinction. Nebuchadnezzar raided Judah when his
army descended from Babylon in sixth-century BC, destroying its cities and exiling its
people. 2 Kings 25; Jeremiah 39. In contrast, the Continental Congress did not raid Great
Britain when it declared that the 13 colonies were “absolved from all allegiance to the
British Crown” and were free and independent states. T HE D ECLARATION OF
I NDEPENDENCE (U.S. 1776).
But even if the former employees leaving and starting a new competing firm wasn’t,
by definition, a raid, Salomon claims the subsequent solicitation of clients and taking of
over $300,000,000 in assets was. Using our historical example, Salomon might argue that

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even if the colonists didn’t technically raid the British when they declared independence,
they did so when they took arms and ammunition from British depots. While that argument
might have some initial appeal, the text of the Protocol suggests otherwise.
Recall that the Protocol says that “[i]f departing [financial advisor]s and their new
firm follow this protocol, neither the departing [financial advisor] nor the firm that he or
she joins would have any monetary or other liability to the firm that the [financial advisor]
left by reason of the [financial advisor] taking the information identified below or the
solicitation of the client serviced by the [financial advisor] at his or her prior firm.” J.A.
250. This means that, under the Protocol, taking clients is generally not actionable against
either the departing advisor or the new firm they join. True, this language is followed by
the language of the raiding exception permitting a prior firm to sue another firm for raiding.
But if raiding captures the mere taking of clients, that would conflict with, if not nullify
and render superfluous, the language absolving the departing financial advisors and new
firm for doing just that. See Funkhouser v. Spahr, 46 S.E. 378, 380 (Va. 1904) (“[O]ne of
the established canons of construction, as we have seen, is that effect shall be given to
every word in the instrument to be construed, whether it be a will, a contract, a statute, or
a constitution.”); see also A NTONIN SCALIA & BRYAN G ARNER , READING L AW: THE
I NTERPRETATION OF L EGAL T EXTS 174 (2012) (“If possible, every word and every
provision is to be given effect . . . . None should be ignored. None should needlessly be
given an interpretation that causes it to duplicate another provision or to have no
consequence.”). To avoid superfluidity, “raid” must mean something else. And as already
described, it refers to intruding conduct by an outside firm to steal away employees.

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2. The Ordinary Meaning
Second, the ordinary meaning of raiding also refers to a competing firm swooping
in to lure employees away from their current employer—not a means of keeping employees
from striking out on their own. See TravCo Ins. Co. v. Ward, 736 S.E.2d 321, 325 (Va.
2012) (stating that in interpreting a contract, “[w]ords that the parties used are normally
given their usual, ordinary, and popular meaning” (internal quotation marks omitted)
(quoting City of Chesapeake v. States Self-Insurers Risk Retention Group, Inc., 628 S.E.2d
539, 541 (Va. 2006))).4
One tool for determining the ordinary meaning of a word is dictionaries. Blakely v.
Wards, 738 F.3d 607, 611 (4th Cir. 2013) (en banc) (stating that when determining whether
a word’s meaning is plain, “we customarily turn to dictionaries for help” (internal quotation
marks and citation omitted)). Using dictionaries from around the time the Protocol was
drafted, “raid” is defined as “a sudden, hostile attack.” Raid, WEBSTER ’ S N EW W ORLD
COLLEGE D ICTIONARY (4th ed. 2004); see also Raid, N EW W EBSTER ’ S D ICTIONARY (2004)
(defining “raid” as “a hostile incursion, a foray”). Even definitions more specific to the
4 Neither of the parties briefed, nor does the Protocol address, what law governs the
interpretation of the Protocol. Under Virginia law, “the law of the place where the contract
was formed applies when interpreting the contract and determining its nature and validity.”
Dreher v. Budget Rent-A-Car Sys., Inc., 634 S.E.2d 324, 327 (Va. 2006). And a contract
arises “when the last act to complete it is performed.” Res. Bankshares Corp. v. St. Paul
Mercury Ins. Co., 407 F.3d 631, 635 (4th Cir. 2005) (quoting Seabulk Offshore, Ltd. V.
Am. Home Assurance Co., 377 F.3d 408, 419 (4th Cir. 2004)). Here, in the absence of any
contravening evidence, it appears Virginia law would apply as Salomon and Founders
Grove likely signed the Protocol in Virginia, where they conduct business.

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corporate context similarly suggest intrusion by an outsider. See Raid, W EBSTER ’S N EW
W ORLD COLLEGE D ICTIONARY (4th ed. 2004) (alternatively defining “raid” as “an attempt,
as by a business concern, to lure employees from a competitor”); see also Raid, BLACK ’ S
L AW D ICTIONARY (8th ed. 2004) (defining “raid” as “[a]n attempt by business . . . to lure
employees . . . from a competitor”). Like the text, these definitions suggest that the
Protocol contemplates a separate firm taking employees away from Salomon—not
employees of that firm leaving of their own accord.
Another tool, corpus linguistics, largely affirms this general understanding of the
term “raid.” “Corpus linguistics is the study of language (linguistics) through systematic
analysis of data derived from large databases of naturally occurring language (corpora, the
plural of corpus, a body of language).” Thomas R. Lee & James C. Phillips, Data-Driven
Originalism, 167 U. Pa. L. Rev. 261, 289 (2019). “In layman’s terms, corpus linguistics
clarifies a term’s meaning by studying the term’s use across specified time periods and
origins.” United States v. Boler, 115 F.4th 316, 332 (4th. Cir. 2024) (Quattlebaum, J.,
dissenting). By searching the term “raid,” and then reviewing each use in its context, “a
broad picture of how a word or phrase was customarily used and understood during a
specified time period can emerge.” United States v. Rice, 36 F.4th 578, 583 n.6 (4th Cir.
2022). To start, the Corpus of Contemporary American English (“COCA”) “contains over
one billion words of text . . . from eight genres: spoken, fiction, popular magazines,
newspapers, academic texts, TV and movie subtitles, blogs, and other web pages” spanning
1990 through 2019. Corpus of Contemporary American English, https://www.english-
corpora.org/coca/ [https://perma.cc/9JQP-9M42] (last visited July 30, 2025).

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Searching the word “raid” for uses between 2000 and 2009, the years surrounding
the Protocol’s drafting, produced 2085 hits. COCA’s random sampling function pulled 100
hits from that total, which are attached as an appendix. And while not all of the uses of
“raid” in the sample contain sufficient context to lend support here, many uses do—
affirming that a raid involves hostile intrusion. For example, 11 of the 100 samples
reference some form of aerial raid between hostile parties, including well-known air raids
of World War II between Germany and Great Britain. Another 10 reference law
enforcement or investigative raids in connection with criminal activity. Even biology lends
support to our understanding of the term raid. Natural History Magazine describes a
specific bird’s tendency to “raid spider webs for ensnared arthropods.” Spanning
differences in discipline, medium and time, corpus linguistics affirms that a raid requires
one party attacking another—not merely a faction of a group leaving.
3. The Industry-Specific Meaning
Finally, even if we accept the district court’s definition of raiding from the financial
services industry, raiding necessarily requires an outside firm. The article the district court
largely relied on says so. John D. Finnerty et al., Calculating Damages in Broker Raiding
Cases, 11:2 Stan. J.L. Bus. & Fin. 261, 262–63 (2006) (“In a field where authorities have
difficulty agreeing upon the very definition of raiding, how does a practitioner or party
know when the case at hand involves a raiding claim? A recent legal conference on raiding
in the securities industry attempted to answer this very question, eventually defining
raiding as a ‘compensable hiring of producers in a definable business unit of one firm by
a competing firm.’” (second emphasis added)). This makes sense because otherwise raiding

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would be reduced largely to a numbers game based on some percentage of economic impact
to the old firm. Imagine two partners form a financial services shop. After a while, a
personality conflict develops. One decides to start a new endeavor and departs, complying
perfectly with the Protocol. So long as a significant number of clients decided to stick with
him at his new firm, there would likely be liability for raiding under the district court’s
definition.5 But if that same professional worked at a large enough firm and the percentage
was not triggered on his departure, there would not be raiding. This goes too far.
To summarize, defendants’ conduct could not constitute raiding for two reasons.
First, four of the five defendants are individuals. And the Protocol’s plain text establishes
that the raiding exception applies only to firms. Second, the remaining entity defendant,
Founders Grove, did not seek to lure employees away from Salomon. It was created by the
former employees so that they could start a new endeavor after resigning from Salomon
using the very information they were expressly permitted to take under the Protocol. Such
conduct is not raiding under the text of the Protocol or as the term is understood by its
ordinary meaning or its meaning in the financial services industry. Thus, we decline to
affirm the preliminary injunction based on the Protocol as to either the former employees
or Founders Grove.
5 Even more problematic of a result, the departing partner might not even ask clients
to move with him. But so long as enough chose to transfer to his new firm, that would be
sufficient to constitute a raid without any affirmative conduct of the partner.

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B. The Agreements
But just because defendants’ conduct does not constitute raiding under the Protocol
does not mean the injunction was improper. “[W]e are not limited to evaluation of the
grounds offered by the district court to support its decision, [and we] may affirm on any
grounds apparent from the record.” United States v. Smith, 395 F.3d 516, 519 (4th Cir.
2005); see also S.E.C. v. Fife, 311 F.3d 1, 8 (1st Cir. 2002) (“We may affirm the district
court’s grant of a preliminary injunction . . . on any grounds supported by the record.”).
The plain language of the Agreements provides such an alternative ground for finding
likelihood of success on the merits as to the former employees, but not as to Founders
Grove.
Under Virginia law, “[t]he pole star for the construction of a contract is the intention
of the contracting parties as expressed by them in the words they have used.” Ames v. Am.
Nat’l Bank of Portsmouth, 176 S.E. 204, 216 (Va. 1934) (emphasis in original); see also
TM Delmarva Power v. NCP of Virginia, 557 S.E.2d 199, 200 (Va. 2002) (“Contracts
between parties are subject to basic rules of interpretation. Contracts are construed as
written, without adding terms that were not included by the parties.”). The words used by
the parties in the Agreements indicate that the Protocol does not apply to Winters, Atwood,
Thompson and Sorensen. Recall, the Agreements state:
The parties to this agreement acknowledge that [Salomon] is not part of or
subject to Broker Protocol. In the event [Salomon] elects to join the Broker
Protocol, the parties further agree that this agreement shall take precedence
over and shall apply, regardless of the terms of the Protocol for Broker
Recruiting and that this agreement shall apply and control in the event that
any term of this agreement conflicts with any term of the Protocol for Broker
Recruiting.

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J.A. 56, 71, 85, 99 (capitalization altered).
Under that language, if Salomon was not a member of the Protocol, the Agreements
would control. And if Salomon became a member of the Protocol, the Agreements would
also control. But does that leave a contractual gap where, as here, Salomon was already a
member at the time the Agreements were signed? Perhaps. But the text of this provision,
read as a whole, indicates that the Agreements prevail over the Protocol whether or not
Salomon is a member. Precisely when Salomon became a member does little to change
that. And to accept any other reading would contravene Virginia law, which prohibits us
from “read[ing] into contracts language which will add to or take away from the meaning
of the words already contained therein.” Wilson v. Holyfield, 313 S.E.2d 396, 398 (Va.
1984). Put simply, the meaning of the words here indicate the Agreements control over the
Protocol regardless of Salomon’s Protocol-membership status.
With that issue settled, the non-solicitation and confidentiality provisions of the
Agreements likely prohibit the former employees’ conduct. Indeed, the former employees
all but admitted below, and do not dispute on appeal, that “[Salomon]’s client information
constitutes a trade secret” and that they took it with them to start Founders Grove. Salomon,
841 F. Supp. 3d at 405. Thus, Salomon has shown a strong likelihood of success on the
merits of its trade secrets claims as to the former employees.
However, the district court’s preliminary injunction broadly enjoined all defendants,
including the newly formed entity, Founders Grove. And Founders Grove was not a party
to the Agreements. Therefore, it cannot be enjoined on that basis. Of course, Winters and

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Atwood are the members of Founders Grove, and all four individuals are now employees
at Founders Grove. To be clear, the injunction as to the former employees extends to
actions they take on behalf of Founders Grove. But to the extent the district court
preliminarily enjoined Founders Grove itself, we find that was an abuse of discretion. 6
Because the former employees’ main line of attack was that they should enjoy the
protections of the Protocol, they hardly marshal a defense under the Agreements on
irreparable harm,7 balance of equities or public interest. In the absence of any argument to
the contrary, we find no abuse of discretion in the district court’s assessment of the
remaining Winter factors as to the former employees under the Agreements.
6 While we vacate the injunction as to Founders Grove, we make no determination
on the merits of Salomon’s trade secret claims, or any other claims, against it.
7 Irreparable harm requires a plaintiff to make a “clear showing that it will suffer
harm that is neither remote nor speculative, but actual and imminent.” Mountain Valley,
915 F.3d at 216 (internal quotation marks and citation omitted). “[P]ermanent loss of
customers to a competitor or the loss of goodwill” constitutes irreparable injury. Multi-
Channel TV Cable Co. v. Charlottesville Quality Cable Operating Co., 22 F.3d 546, 552
(4th Cir. 1994), abrogated on other grounds by Winter v. Nat. Res. Def. Council, Inc., 555
U.S. 7 (2008); see also Update, Inc. v. Samilow, 311 F. Supp. 3d 784, 796 (E.D. Va. 2018)
(“[T]he Fourth Circuit has repeatedly recognized that the threat of a permanent loss of
customers and the potential loss of goodwill also support a finding of irreparable harm.”
(cleaned up)). Here, Salomon has identified millions of dollars transferred in the weeks
following defendants’ announcement. And the quantity of accounts lost here is
substantial—449 at the time of the district court’s preliminary injunction hearing. While
money alone does not constitute irreparable harm, here it serves as a tangible indicator of
intangible losses—such as lost goodwill, lost customer trust and damage to reputation. See
Coreth, 535 F. Supp. 3d at 517–18 (finding that “evidence of lost customers, lost goodwill,
lost customer trust, and damage to reputation,” as evidenced by lost accounts, satisfied
irreparable harm).

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III.
In sum, the district court did not abuse its discretion in granting the preliminary
injunction as to the former employees. It did, however, abuse its discretion in granting the
preliminary injunction as to Founders Grove. Therefore, the district court’s order is,
AFFIRMED IN PART AND VACATED IN PART.

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APPENDIX
Year Source Type and
Source
Excerpt of Concordance Line
1 2004 Magazine:
Harper’s
Magazine (Mar.)
. . . a T-shirt salesman, his military background and
media ambitions inspired him to enter
the Raid Gauloises, an annual French race that
sent teams on rugged courses through the . . .
2 2006 Newspaper: New
York Times (Jan.
15)
. . . On Saturday, a Central Intelligence Agency
spokesman declined to comment on any raid that
might have taken place. The agency is known to
operate armed Predator aircraft . . .
3 2003 Spoken: CBS, 60
Minutes (Mar. 30)
. . . No one knows for certain. BRADLEY: Shortly
after the raid on Orao, Croatian authorities, acting
on a tip from U.S. intelligence, intercepted . . .
4 2003 Fiction: Analog
Science Fiction &
Fact (Nov.)
. . . that will let us into the ship.” “Bring an enemy
to the raid.” Blake was incredulous. “Bring a
defector. An ally. That . . .
5 2004 Magazine: People
(Apr.)
. . . “I was up to no good,” he says. “The raid was
a turning point. I knew I had to get on the right
path . . .
6 2004 Newspaper: New
York Times (Oct.
23)
. . . tipped that Mr. Khashiyev was in the house,
General Shabalkin said. The raid began at about
6:20 p.m., when roughly 50 Russians surrounded
the house, survivors . . .
7 2001 Spoken: National
Public Radio, All
Things
Considered (Nov.
22)
. . . the cops just blew on in here, and we’re in
some kind of raid. I just hope they will release us
for the Thanksgiving day parade. . . .
8 2007 Academic: Church
History (June)
. . . representatives of the federal justice
department who conducted a raid in which
polygamists (mainly males) were arrested and
imprisoned, . . .
9 2004 Newspaper: San
Francisco
Chronicle (Nov.
17)
. . . along the length of the side wall and into a
crevice. Visitors asked for Raid. I declined. I
didn’t spray them with soapy water or put down .
. .
10 2006 Fiction: The
Protectors of
. . . for protection: Durmuk’s troops had been
crossing through Plothy Pass almost daily
to raid border settlements (furious denials from

-- 19 of 28 --

20
Science Fiction
(June)
the uniformed men) and were massing in great . .
.
11 2003 Magazine: Sports
Illustrated (Feb.)
. . . Gordon and Johnson start howling with
laughter-it’s all a goof, a snapshot panty raid. As
Sadler puts the camera away, Gordon pulls out a
felt-tip pen and . . .
12 2007 Movie: Bats:
Human Harvest
. . . nuclear, biological, chemical. Target the
source, stop distribution. Your Iraqi raid exposed
a network that is hell bent on acquiring these
weapons. Key money men . . .
13 2008 Spoken: National
Public Radio, Tell
Me More (Mar.
14)
. . . Thank you. Hello. MARTIN: Juan, Uribe had
to know the cross-border raid would raise hackles.
Why did he think it was worth it? FORERO: . . .
14 2004 Spoken: National
Public Radio, All
Things
Considered (Sept.
4)
. . . be smuggled in from nearby Syria into Iraq.
Now the US military launched the raid in the
morning. They say several fighters were killed and
more than a dozen . . .
15 2001 Fiction: Wild
Justice by Phillip
Margolin
. . . you doing here?” “The police,” Grant gasped.
“A raid.” “At the airfield?” “Let me in, for God . .
.
16 2003 Spoken: CNN,
Daybreak (Aug. 4)
. . . in fact, in the past 24 hours, including this
morning. In a raid conducted yesterday, the 4th
Infantry Division that usually operates around
Tikrit in the north . . .
17 2005 Movie: Munich . . . OLYMPICS VILLAGE (NEP STADIUM)
11C The Munich police are suiting up for the raid,
putting on bulky kevlar vests and then track suits
on top of them, . . .
18 2001 Newspaper:
Chicago Sun-
Times (Dec. 13)
. . . ridiculous, but blindly biased. As an example,
three weeks prior to the raid on the Panther
headquarters, there was another event that Dyson
overlooked as he glorified . . .
19 2000 Spoken: ABC,
Good Morning
America (Apr. 24)
. . . I knew the attorney general was acting in good
faith. I never knew a raid had been planned. We
could have arranged, in my opinion, a peaceful . .
.
20 2000 Fiction: A Country
in the Mind by
John L. L. Thomas
. . . The people’s property was at stake, their
money was subsidizing a raid on their own
wealth. “You had better make sure that your
Representatives and . . .

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21
21 2004 Spoken: National
Public Radio,
Daybreak (May
24)
. . . it’s not clear; the military is disputing that. We
had the raid on the headquarters of Ahmad
Chalabi, who was basically our guy in Iraq. . . .
22 2000 Magazine:
Military History
(Feb.)
. . . of the St. Armand area, concerned about their
lack of defense during the Fenian raid of 1866,
sent two representatives south to Massachusetts,
where they bought 40 Ballard . . .
23 2002 Academic:
Archaeology
(July/Aug.)
. . . public during the Second World War.” “The
museum curator was the air raid warden,”
Crummy adds. On the main floors of the museum,
. . .
24 2002 Academic:
American Studies
International
(June)
. . . a white government scout and a white mother.
His mother was killed in a raid by Kiowas and
Comanches, according to Griffis, and he was
taken captive, . . .
25 2009 Academic:
Geographical
Review (Apr.)
. . . in 1925. It replaced one that had been set after
William Quantrill’s 1863 raid. (Photograph by the
author, March 2004) PHOTO (BLACK &; . . .
26 2001 Newspaper:
Denver Post (Nov.
12)
. . . Akber entered Ukraine illegally a month ago
and was captured in a police raid on an apartment
in mid-October. Under Ukrainian law he will be
imprisoned for a . . .
27 2005 Magazine: PC
World (May)
. . . with integrated 802.11g wireless, it offers two
SATA RAID controllers as well as ATA-
133 RAID. Asus added an IDE RAID controller to
the Fatality to augment the 925 and . . .
28 2000 Magazine:
Consumer Reports
(Mar.)
. . . accounts also have built-in disincentives that
prevent you from tapping them prematurely. If
you raid most tax-deferred retirement accounts
before you reach age 59 1/2, for example, you . . .
29 2002 Fiction: Michigan
Quarterly Review
(Fall)
. . . on his last visit to Robert and his bride, had
made a late-night raid on the family refrigerator in
nothing but his undershirt. Crea, hearing the noise
. . .
30 2006 Newspaper: USA
Today (Nov. 13)
. . . of the Army’s 1st Battalion, 23rd Infantry
Regiment, which assisted in the raid. U.S.
investigators believed the compound was run by
al-Sadr loyalists, he says. . . .
31 2005 Television: The
Shield (S4.E6:
. . . seizure policy right now. What are you talking
about? Well, the church raid stirred up a shit

-- 21 of 28 --

22
Insurgents aired
Apr. 19)
storm. So you’re offering me up as a sacrifice. . .
32 2000 Spoken: CNN,
Live Event (Apr.
24)
. . . think that was appropriate? LOCKHART: The
president knew the general details of the raid, and
the president does think that it’s appropriate.
There were – there . . .
33 2001 Magazine: Natural
History
(July/Aug.)
. . . At times of the day when insects are less active,
the birds will raid spider webs for ensnared
arthropods. Like many other hummingbirds, male
bluethroats defend a . . .
34 2003 Spoken: National
Public Radio
Morning Edition
(Apr. 9)
. . . Unidentified Man: Is Saddam Hussein alive?
Was he killed in the air raid over a Baghdad
neighborhood? SMITH: Wasn’t this the way the
war started . . .
35 2009 Television: Dark
Blue (S1.E7:
O.I.S. aired Aug.
26)
. . . Four days after I talked to him… Osiri was
killed in a drug raid led by Fry’s task force. Thing
is - Osiri didn’t sell drugs . . .
36 2009 Academic: ABA
Journal (Apr.)
. . . without a warrant and arrested Callahan. The
Utah state courts ruled the police raid was an
unconstitutional invasion and threw out the
evidence. Callahan then sued Cordell Pearson . . .
37 2001 Newspaper: New
York Times (Oct.
21)
. . . than one service were involved in the overnight
attack, the first major American
commando raid since Somalia nearly a decade
ago. Army Rangers, Green Berets, Navy Seals . . .
38 2009 Newspaper:
Christian Science
Monitor (May 19)
. . . of Iranian-funded Shiite militias involved in
weapons smuggling. One suspect was killed in
the raid and six others detained before Iraqi
authorities ordered their release. One US military
. . .
39 2007 Spoken: Fox
O’Reilly Factor
(Mar. 15)
. . . to Fort Devens for processing and possible
deportation. Massachusetts Governor Deval
Patrick denounced the raid even though the feds
say he was informed about it beforehand, as were
a . . .
40 2006 Newspaper:
Associated Press
(Aug. 2)
. . . (i) Loss (income) from disposal of the IBM i/p
Series RAID business and Systems business,
impairment of the IBM i/p Series RAID long-
lived assets, . . .

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23
41 2007 Spoken: CNN
Newsroom (June
16)
. . . Here now his report. KARL-PENHAUL-
CNN-: U.S. military commanders tell us
this raid took place on June the 9th, but because of
the sensitivity of the information . . .
42 2001 Newspaper: San
Francisco
Chronicle (Sept.
16)
. . . up in the sky. It reminded me I grew up
responding to the air raid signals, with the
automatic duck and cover, with the fear of the
atom . . .
43 2006 Spoken: CNN,
Live (Aug. 12)
. . . And no wonder, the firefighters had not even
cleared the scene when the air raid sirens wailed
again. UNIDENTIFIED-MALE: Very, very, very
dangerous. All the . . .
44 2000 Magazine: Time
(Jan. 24)
. . . Chechens were just biding their time. Last
week guerrillas came out of nowhere to raid three
important towns. Creeping into Argun, mixing
with local residents, attackers assaulted . . .
45 2003 Spoken: CNN,
Daybreak (July
29)
. . . big results. A Saddam Hussein bodyguard, two
associates now in custody. The raid occurred in
Saddam Hussein’s ancestral hometown of Tikrit.
That’s where a lot . . .
46 2005 Newspaper:
Atlanta Journal-
Constitution (Oct.
16)
. . . to drown out the drone of Black Hawk
helicopters lifting off for a three-day raid on a
suspected weapons factory. In Iraq, not even the
church sanctuary . . .
47 2000 Magazine: Boys
Life (Dec.)
. . . air. Pastor Van Heyden sent everyone home
from worship for fear of another bombing raid.
“There are too many planes for that,” Hein’s friend
Piet . . .
48 2006 Newspaper:
Christian Science
Monitor (Apr. 4)
. . . Iraqi Army base here, Iraqi and US officers
hash out plans for an evening raid on the home of
a suspected IED maker - the son of insurgent
leader Abu . . .
49 2002 Fiction: Hemlock
Bay by Catherine
Coulter
. . . had brought them down. Savich called all the
agents who had participated in the raid together.
“When the barn doors swung in, did anyone see
anything? . . .
50 2009 Spoken: Fox,
Sunday (Nov. 15)
. . . this -- where was Khalid Sheikh Mohammed
arrested? In Pakistan in a pre- dawn raid. He
wasn’t read his rights. It’s going to be... CHENEY
. . .
51 2006 Spoken: CNN,
Live (Aug. 12)
. . . on that. (COMMERCIAL-BREAK) LIN: A
quick check of the headlines. British

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24
police raid Internet cafes in their search for
evidence in the alleged airline terror plot. They . .
.
52 2008 Magazine:
Military History
(July/Aug.)
. . . Ranger independently, mostly in the Irish Sea.
His first major engagement was a raid on the
British port of Whitehaven on April 22 and 23. It
was hardly . . .
53 2000 Magazine:
Military History
(Feb.)
. . . One night, or rather very early in the morning
the RAF returned from a raid into Germany and,
as usual, dropped a few bombs on our airfield. . . .
54 2001 Newspaper:
Associated Press
(Apr. 16)
. . . leading to the raid. Pictures and informational
graphics showed readers how the raid was
completed in less than three minutes. Other
reporters provided dispatches from Miami’s . . .
55 2007 Newspaper:
Christian Science
Monitor (July 17)
. . . members, in an interview at the US base
Normandy the day after the bombing raid. Mr.
Abdullah and three of his comrades, all Sunnis
from the Jubour . . .
56 2009 Academic:
Geographical
Review (Apr.)
. . . offered defensive aid, to no avail (Cutler
1883). Survivors of the raid, along with
businessmen and politicians, paid for the
monument after raising money through . . .
57 2008 Newspaper:
Washington Post
(Apr. 14)
. . . to gain the confidence of polygamist groups.
“We do fear that this raid is going to have an
impact on those relationships,” said Shurtleff’s
spokesman . . .
58 2005 Television: Night
Stalker (S1.E4:
Burning Man
aired Oct. 20)
. . . ’s our understanding that you haven’t spoken
to anyone in the press since the raid. The raid was
a black mark on the Bureau. Questions were raised
about . . .
59 2001 Spoken: National
Public Radio,
Saturday (May 26)
. . . would finally annihilate their prisoners
outright as they retreated. The heroic story of
that raid to free the prisoners, and of the
persistence of the men inside Cabanatuan, . . .
60 2003 Newspaper:
Washington Post
(July 26)
. . . from the 101st Airborne Division, used great
restraint and limited firepower in
Tuesday’s raid in a concerted effort not to injure
civilians in the neighborhood. “The . . .
61 2002 Spoken: ABC,
Good Morning
America (Sept. 11)
. . . around the country. And we have some
breaking news this morning about an FBI raid in
Baltimore, and ABC’s John Miller joins us now
with the latest on . . .

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25
62 2009 Spoken: PBS,
News Hour (Sept.
10)
. . . it seemed heroic and necessary, but questions
are being asked about whether the raid to rescue a
British journalist and his Afghan colleague was
wise and whether the journalists . . .
63 2000 Spoken: CNN,
Sunday Morning
(Apr. 23)
. . . reporters, cameramen and sound technicians.
Few Miami police patrolled the block where
the raid occurred, but they did set up a perimeter a
few blocks away to contain . . .
64 2008 Television:
Terminator: The
Sarah Connor
Chronicles
(S2.E9:
Complications
aired Nov. 17)
. . . he do? Jess, what did he do to you? There was
a raid on a bunker. Metal was everywhere. They
took out our command, killed . . .
65 2009 Academic:
Geographical
Review (Apr.)
. . . (1883,131). In his book, dedicated to the
victims of Quantrill’s raid, the Lawrence native E.
S. Tucker stated, “This was the most savage . . .
66 2002 Newspaper:
Chicago Sun-
Times (Mar. 17)
. . . from his bed in the middle of a night and
ordered to join an unauthorized raid behind
enemy lines to be led by Patton. The general had
become convinced Hitler . . .
67 2006 Newspaper:
Chicago Sun-
Times (Apr. 18)
. . . House of Representatives, is elected secretary
of state. March 1993: Investigators raid a
secretary of state facility in Libertyville to probe
allegations that driver’s licenses are . . .
68 2005 Newspaper: New
York Times (Oct.
22)
. . . no links to the case who were taken to the
gallows by mistake. Raid Juhi, the investigative
judge who spent hours questioning Mr. Hussein
and other defendants in . . .
69 2009 Spoken: Fox:
Glenn Beck (Sept.
14)
. . . of the essence. Back in a minute. BECK:
There’s another terror raid. You know, I ask that
we keep our police officers and our fire . . .
70 2005 Magazine: Time
(Feb. 7)
. . . Its imam and congregation are known to be
hostile to U.S. forces. The raid’s focus shifts to a
building marked as House 69 on the soldiers’
maps . . .
71 2007 Magazine: Ms.
Magazine (Spring)
. . . More QM Blog From Iraq. Here, a short
excerpt about a neighborhood raid by “security
forces” on the night of Riverbend’s cousin J’s 16th
. . .

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26
72 2001 Magazine: PC
World (July)
. . . Athlon CPU, 256MB of DDR SDRAM, two
3oGB hard drives in an IDE RAID configuration,
and MicroSoft Office 2000 Professional. The
MTower SP’s 16X/10X/40X CD-RW drive . . .
73 2003 Spoken: CNN,
Live (Dec. 20)
. . . 21 crewmen are now in U.S. Naval custody.
Today’s arrests follow Monday’s raid on another
vessel that turned up nearly $10 million of hashish
and linked some of . . .
74 2003 Newspaper:
Atlanta Journal-
Constitution (Oct.
15)
. . . about a dozen villagers in central Henan were
beaten up and arrested in a night raid after more
than 100 of them protested for better medical care.
In August, . . .
75 2002 Magazine:
Military History
(June)
. . . took 6,000 infantry and 1,000 cavalry, telling
them they were going on a night raid against
Hannibal. Obviously, he was doing everything
possible to keep Hannibal in the . . .
76 2009 Television:
Battlestar
Galactica
(S4.E13: The Oath
aired Jan. 30)
. . . this place was down here. Yeah, everybody did.
Got trashed during the raid on New Caprica, but I
brought it back online for this. I came . . .
77 2003 Spoken: National
Public Radio,
Daybreak (Oct.
20)
. . . was disclosed that there were samples of
substances that might be steroids found during
the raid. Right now, as far as we know, the reason
that they want . . .
78 2001 Magazine:
Military History
(June)
. . . and a strong detachment shadows the enemy
army, preventing it from fanning out to raid and
pillage. The dogging force snipes at the enemy’s
rear until the raiders . . .
79 2007 Newspaper:
Atlanta Journal-
Constitution (Apr.
14)
. . . the way. RUSTY CARTMILL, Alpharetta
Fascist police became crooks in poker raid
Criminals brazenly barged into a nice Roswell
home in a quiet neighborhood on Monday . . .
80 2002 Spoken: CNN,
Saturday Morning
(Oct. 26)
. . . in Moscow and that’s where we’re headed now.
That is a predawn raid. It ended a three day
hostage stand-off that saw Chechen rebels
threatening to kill . . .
81 2001 Spoken: National
Public Radio,
Saturday (Aug.
25)
. . . ? -- come to think of it. Mr-SHEARER:
No. SIMON: Standard air raid. Mr-SHEARER:
Business as usual, yeah. SIMON: Until the middle
of . . .

-- 26 of 28 --

27
82 2003 Academic: Journal
of American
Ethnic History
(Spring)
. . . in the city’s red light district via the Galveston
movement, Fox organized a raid with the mayor
and police commissioner. The women were told to
mend their ways . . .
83 2003 Newspaper: USA
Today (May 14)
. . . whether Saudi law enforcement may have
botched an opportunity to stop the attacks when
its raid on a home here last week went awry and
the suspected al-Qaeda members escaped. . . .
84 2005 Newspaper:
Atlanta Journal-
Constitution (Apr.
16)
. . . by helicopter after one broke his leg and the
other hurt his back during the raid on Al Jaff.
Missions continue throughout the day and night,
and the . . .
85 2008 Magazine: PC
World (July)
. . . $500 without drives) This storage device uses
disk and storage virtualization algorithms instead
of RAID 5 to provide data redundancy. 41 Google
Gmail (e-mail, free) Google . . .
86 2005 Spoken: CBS, 60
Minutes (Feb. 23)
. . . On this night, they’d entered into the most
dangerous part of the city to raid a
telecommunications building where they believed
three insurgents were hiding. As they forced their
. . .
87 2000 Newspaper:
Associated Press
(July 11)
. . . which owns part of the television station, news
reports said. The raid on Media-Most was the
second in three months, and it followed the arrest
last . . .
88 2001 Newspaper:
Washington Post
(Dec. 13)
. . . in real life. His comparison of nerve gas to
household bug killers like Raid is “wrong info,”
they said, as was his stating that the . . .
89 2004 Magazine: Good
Housekeeping
(Feb.)
. . . Mark is about to break onto the big screen in
the war drama The Great Raid, the couple remain
committed to each other and to their family: “We
. . .
90 2009 Fiction: Fantasy &
Science Fiction
(Feb.)
. . . was the last time we got lucky in anything?”
He meant the last raid north into the Colorado free
state, where rebel hostiles had an ambush waiting
for . . .
91 2008 Academic: Social
Work (Jan.)
. . . assess detained adults transferred to Fort
Devens in Massachusetts in the immediate
aftermath of the raid and then flew two teams to
detention centers in El Paso and Harlingen, Texas
. . .

-- 27 of 28 --

28
92 2005 Television: Law &
Order: Special
Victims Unit
(S7.E6: Raw aired
Nov. 1)
. . . least you got them. You’re gonna like this.
During the subsequent raid, we found some
information at may be pertinent to your case.
WHITLOCK RESIDENCE . . .
93 2006 Spoken: CNN,
Lou Dobbs
Tonight (Oct. 25)
. . . boldly brandishing weapons just hours after
Iraqi special forces and their U.S. advisers
launched a raid against, according to the U.S.
military, a top death squad commander. Later . . .
94 2002 Newspaper:
Christian Science
Monitor (Jan. 28)
. . . six choppers that lifted off into the blue sky,
ending another dramatic anti-Al Qaeda raid in
eastern Afghanistan. The two-day operation -
which amounted to a siege and a . . .
95 2004 Fiction: SpinState
by Chris Moriarty
. . . while the AI goes fishing. We’re after whatever
you can get on this raid. Source code, hardware,
wetware. Especially wetware. Once the AI has . .
.
96 2007 Newspaper:
Associated Press
(June 6)
. . . and Iraqi Kurds act on their appeals for a
crackdown on separatist fighters,
who raid southeast Turkey after resting, training
and resupplying at bases in northern Iraq. . . .
97 2006 Spoken: CNN,
Situation Room
(June 12)
. . . of nowhere and hit a market in Balad. Seven
terrorists were killed in a raid in Baquba. During
that raid, officials say two boys, ages six months .
. .
98 2005 Television: 24
(S4.E6: Day 4:
12:00 p.m.-1:00
p.m. aired Jan. 24)
. . . The White House has confirmed that the
interrupted video transmission was caused by
a raid mounted by the marines and the Counter
Terrorist Unit who rescued secretary of defense
James Heller moments ago . . .
99 2004 Spoken: CNN,
Live Sunday (May
9)
. . . The smoldering Shiite uprising reignites in
Baghdad’s Sadr city. Following an
American raid overnight, that netted two top
deputies of militant Shiite cleric Muqtada al-Sadr.
. . .
100 2001 Spoken: NBC,
Dateline (July 30)
. . . tell psychologists that he had killed a mother
and her four small children during a raid on a
Vietnamese village. And while Army records
make no mention of the incident . . .

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