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New Treasury Guidance Provides Relief from Financial Instrument Offering under Payroll Support Program for Small and Mid-Sized Aviation Businesses

Client Alert | 1 min read | 04.14.20

Treasury recently announced additional guidance regarding the Payroll Support Program under Title IV of the CARES Act, which provides payroll support for American workers employed by passenger air carriers, cargo air carriers, and certain contractors to Part 121 air carriers. This guidance modifies Treasury's earlier requirement that applicants offer warrants, options, preferred stock, debt securities, notes, or other financial instruments as compensation for the provision of payroll support. 

Recognizing the difficulty that small and mid-sized aviation businesses face in making such an offer, Treasury decided that it will not require passenger air carriers that receive $100 million or less in payroll assistance to provide financial instruments as appropriate compensation. Because Treasury will not need to evaluate financial instruments proposed by passenger air carriers qualifying for this exception, funds will be available to those air carriers promptly upon approval of their applications.

This exception does not apply to passenger air carriers whose allocated payments would exceed $100 million, or to cargo carriers or contractors. Treasury is expected to provide further guidance for those applicants in the near future. Additional guidance about this program can be found in our previous client alert.

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Client Alert | 4 min read | 12.04.25

District Court Grants Preliminary Injunction Against Seller of Gray Market Snack Food Products

On November 12, 2025, Judge King in the U.S. District Court for the Western District of Washington granted in part Haldiram India Ltd.’s (“Plaintiff” or “Haldiram”) motion for a preliminary injunction against Punjab Trading, Inc. (“Defendant” or “Punjab Trading”), a seller alleged to be importing and distributing gray market snack food products not authorized for sale in the United States. The court found that Haldiram was likely to succeed on the merits of its trademark infringement claim because the products at issue, which were intended for sale in India, were materially different from the versions intended for sale in the U.S., and for this reason were not genuine products when sold in the U.S. Although the court narrowed certain overbroad provisions in the requested order, it ultimately enjoined Punjab Trading from importing, selling, or assisting others in selling the non-genuine Haldiram products in the U.S. market....