CLAY, Circuit Judge. Plaintiffs Higuchi International Corporation and Higuchi Manufacturing Mexico S. de R.L. de C.V. (collectively, “Higuchi”) appeal the district court’s grant of a preliminary injunction to Defendant Autoliv ASP, Inc. (“Autoliv”). Higuchi, an automotive parts supplier, brought this declaratory judgment action against Autoliv, seeking a declaration that it was not obligated to supply automotive parts to Autoliv because the parties lacked an enforceable requirements contract. Autoliv thereafter filed a breach of contract counterclaim and moved for a preliminary injunction to direct Higuchi to supply automotive parts pending the resolution of the parties’ suit. The district court granted Autoliv’s motion for a preliminary injunction. For the reasons set forth below, we REVERSE the district court’s order and REMAND for further proceedings consistent with this opinion.

Kevin Gene Steiling of Franklin died May 25 at the age of 69. A 1983 graduate of the Boston College Law School, Steiling moved to Nashville and began his lengthy career at the Tennessee Attorney General’s Office. From 1983 to 2016, he served as an assistant attorney general and then a deputy attorney general working on civil rights, employment discrimination and contract and construction litigation with jury and non-jury trials in federal and all state courts and the Sixth Circuit Court of Appeals. Steiling also spent three years working in the Massachusetts Attorney General’s Office as an assistant attorney general in the Trial Division/Real Estate Section, handling eminent domain cases. A memorial gathering will be held on June 8 from 1-4 p.m. at Williamson Memorial Funeral Home, 3009 Columbia Ave., Franklin 37064.

Richard Randolph Ruth Jr. of Walden died May 25 at the age of 86. Originally from Pennsylvania, Ruth earned his law degree from the University of Tennessee College of Law in 1965. He practiced in Chattanooga from 1965 until 2002, including time with the Hamilton County District Attorney’s Office; Luther, Anderson, Ruth & Cleary; Ruth & Foster; and Ruth & McCarthy. After retiring, Ruth volunteered with the Legal Aid of East Tennessee and was instrumental in advocating for the Tennessee Supreme Court’s adoption of the “Pro Bono Emeritus Rule” in 2010, which provides special status to retired attorneys who volunteer to assist indigent clients. Ruth also was honored with the Jac Chambliss Lifetime Achievement Award from the Chattanooga Bar Association in 2010. A private memorial service will be held for the family. Memorial contributions may be made to Legal Aid of East Tennessee, National Kidney Foundation or Tennessee Valley Railroad Museum.

The upcoming TBA Convention offers eight hours of CLE programming, including Friday’s session on “Preventing Attorney Burnout.” Sponsored by the TBA's Attorney Well Being Committee, the program will feature retired Judge Robert "Butch" Childers, now with Childers Mediation and Arbitration Services, and Tennessee Lawyers Assistance Program Executive Director Buddy Stockwell — two seasoned lawyers with extensive experience and knowledge in the field of attorney well-being. The discussion will be moderated by Chase Pittman with the Kardia Collective, a Memphis-based counseling company. Learn more about this program or other CLEs being offered at this year's convention.

Microsoft 365 offerings combine an always up-to-date install of Microsoft Office with email hosting, mobile apps and web-based apps. Compare Microsoft’s 365 options with this link. Find this and more in the Opening a Firm section of TBA’s Law Practice Management Center.

The Immigration Law Section will present its annual forum this Friday at Casa Azafran in Nashville. This is one CLE you want to attend in person! The agenda is packed with speakers from government agencies, but their session will not be recorded or made available later due to government agency policy. Don't miss hearing from representatives from the U.S. Citizenship & Immigration Services (USCIS) Nashville, U.S. Immigration & Customs Enforcement’s (ICE) Enforcement & Removal Operations, ICE Office of the Principal Legal Advisor (OPLA), and the USCIS Asylum Office. Other speakers will provide updates on the EB-5 Immigrant Investor Program and F-1 and J-1 programs.

Nashville School of Law (NSL) celebrated its 116th commencement ceremony conferring law degrees on 69 graduates. NSL Dean William C. Koch Jr.; Aubrey B. Harwell Jr., chair of the NSL Board of Trust; and commencement speaker Tennessee Court of Appeals Judge W. Neal McBrayer shared messages with attendees. In his keynote address, McBrayer stated that ambitious NSL graduates could become outstanding lawyers by championing pro bono work. “It strikes me that the great attorneys tend to have one thing in common: sharing their skills free of charge where there is a need for legal services.” Read more in a press release from the school and see pictures from the event.

Gov. Bill Lee has signed SB2763, a preemption bill that blocks any local Tennessee municipality from passing its own version of an extreme risk protection order or "red flag" law, which could remove guns from individuals deemed a threat. The bill passed in the final days of session, a year after Lee failed to pressure lawmakers into a vote over his version of an extreme risk measure following the Covenant School shooting. The Tennessean has the story.

The National Collegiate Athletic Association (NCAA) along with the Atlantic Coast Conference, Big Ten, Big 12, Pac-12 and Southeastern Conference last week announced they will pay nearly $2.8 billion to settle several antitrust claims that could force schools to share athletics-related revenue with their athletes, reports the AP. Tennessee Attorney General Jonathan Skrmetti on Friday released the following statement: "While our case is a little different than House v. NCAA, it seems like by and large we all want the same thing: for the NCAA to follow the law and for our student-athletes to have a clearly defined set of rules that give them a fair share of the revenue they generate. For decades, the NCAA and adjacent entities have made billions of dollars from the tireless work of kids playing sports, while fighting to keep these student-athletes from negotiating market compensation. The NCAA’s behavior has been illegal and unfair, which is why we filed our suit and why a federal judge ruled in our favor and issued a preliminary injunction to stop the NCAA’s illegal behavior. We will run every legal play in the book to protect Tennessee’s student-athletes."

We've got news for you! The TBA YLD newsletter will have a new section next month: What Have You Been Up To? We are interested in sharing your news of significant life events, including marriages, birth/adoption announcements, travel and special awards and recognitions. If you have good news to share, please fill our our online form. We can't wait to read all about your news!