On April 14, 2026, the First Department issued a decision in T-Mobile USA, Inc. v. Broadcom Inc., 2026 NY Slip Op. 02226, ordering a trial court to reconsider the amount of a bond because it was insufficiently related to the damage that could result from an injunction, explaining:
[T]he amount of the undertaking ($500,000) was not rationally related to defendants’ potential damages should the preliminary injunction later prove to have been unwarranted, such as the cost to defendants of providing special services to plaintiff. Therefore, we remand for further proceedings on this issue.
(Internal quotations and citations omitted).