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'[T]he fair notice requirement of Rule 65(d) must be applied `in the light of the circumstances surrounding [the order's] entry.'' Common Cause v. Nuclear Reg. Comm'n, 674 F.2d 921, 927 (D.C.Cir.1982) (quoting United States v. Christie Indus., Inc., 465 F.2d 1000, 1002 (3d Cir.1971)). The recipient of a TRO, which usually takes effect immediately, should not be left guessing as to what conduct is enjoined. The benchmark for clarity and fair notice is not lawyers and judges, who are schooled in the nuances of trademark law. The 'specific terms' and 'reasonable detail' mandated by Rule 65(d) should be understood by the lay person, who is the target of the injunction. This is a circumstance, among many in the legal field that cries out for 'plain English.'
