CelLink Corp. v. Manaflex LLC

I. BACKGROUND

18 On August 18, 2023, Plaintiff filed suit against Defendant Manaflex LLC (“Manaflex”) 19 alleging patent infringement and trade secret misappropriation. See Dkt. No. 1. Plaintiff owns 20 U.S. Patent No. 11,116,070 (the “’070 Patent”), which covers “new methods of forming 21 interconnect circuits that provide new designs and functionalities of these circuits.” Id. ¶ 28. 22 Plaintiff alleges that Manaflex manufactures products using the method(s) claimed in the ’070 23 Patent. Id. ¶¶ 26–34. Plaintiff also accuses Manaflex of trade secret misappropriation under the 24 Defend Trade Secrets Act, 18 U.S.C. § 1836. As alleged in its complaint, Plaintiff allegedly 25 disclosed trade secrets regarding “innovative fabrication and manufacturing techniques . . . critical 26 to achieving [Plaintiff’s] best-in-class battery optimization and efficiency” to Robert Lane and 27 Augusto Barton, former Tesla employees, pursuant to a mutual non-disclosure agreement executed on April 16, 2016 (“MNDA”). Id. ¶¶ 38–43. Plaintiff alleges that in April 2016, it “approached Tesla to discuss [Plaintiff’s] unique product capabilities,” and in October 2015, Tesla contacted …