and injunc-tive relief in a contract case. See Marlyn Nutraceuticals, Inc. v. Mucos Pharma GmbH & Co., 571 F.3d 873, 878-79 (9th Cir. 2009). Perhaps recognizing the difficulty in distinguishing between specific performance and injunctions, courts often characterize requests for specific performance of contractual duties as requests for injunctive relief. See Power P.E.O., Inc. v. Amps. Ins. of Wausau, 201 Ariz. 559, 38 P.3d 1224, 1228 (Ariz. Ct. App. 2002). (“Indeed, courts frequently characterize an injunction preventing a party from breaching a contract as an order of specific performance.”) (citing Daley v. Earven, 131 Ariz. 182, 639 P.2d 372 (Ariz. Ct. App. 1981)); see also Lansmont Corp. v. SPX Corp., No. 5:10-cv-05860 EJD, 2012 WL 6096674, at *5-6 (N.D. Cal. Dec. 7, 2012) (<HOLDING>). Likewise here, where the parties have not
recognizing a permanent injunction as a means of ordering specific performance holding that where a temporary order is later made permanent the permanent order may be challenged holding it was error for the court to issue a permanent injunction at a hearing to show cause why a temporary restraining order should not be continued via a preliminary injunction holding preliminary injunction improper where it exceeded the relief sought and granted the same relief which would have been given in a final order of permanent injunction recognizing the importance of a determination on the merits with respect to the issuance of a permanent injunction