LAY, Chief Judge.
Merrill Lynch, Pierce, Fenner & Smith, Inc. sought injunctive relief against five former employees to prevent their use of Merrill Lynch's records and their solicitation of Merrill Lynch clients. The employees counterclaimed seeking to compel arbitration under the Federal Arbitration Act, 9 U.S.C. §§ 1-4 (1982). The district court granted injunctive relief
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