In the previous litigation, plaintiff claimed copyright infringement against the defendant and obtained a default judgment. The court then denied the defendant's motion to overturn the default and entered a final judgment and permanent injunction. The defendant appealed to the Fifth Circuit, and also filed counter-sued in India, claiming the plaintiff in the previous litigation filed a frivolous and defamatory lawsuit. Plaintiff moved for an anti-suit injunction.
The court found that the litigation in India is somewhat duplicative of the previous litigation, but it also contained additional claims that were not present in the previous litigation. The court therefore issued the anti-suit injunction only as to the duplicative claims.
Partial anti-suit injunction! Now that's new. It would be interesting to see how the court in India would react to this decision.