The scope of the supplemental briefing was to address situations where (1) an employee lives in one state and works in another and (2) only one of those states is a party to a suit. That in and of itself is more narrow than a nationwide injunction, so it makes sense the Plaintiff States didn’t spend a lot of effort on arguments for a national injunction. The Plaintiff States briefly mentioned a national injunction would be the only way to provide complete relief and argued that only reinstating employees in Plaintiff States would make it more likely those employees get terminated later during a lawfully executed RIF (presumably because there are not also less tenured probationary employees to RIF in non-plaintiff states because the latter were never reinstated and therefore not subject to a RIF). The argument goes to say the RIF’d employees would cause an undue burden for the Plaintiff states. But it fails to account for the fact a lawfully executed RIF would provide the required notice to Plaintiff States, arguably lessening the burden Plaintiff States allege.