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22 August 2023PatentsMarisa Woutersen

Ex-Tesla workers face suit over China startup

Firm accused of industrial espionage and IP infringement | Dispute concerns integrated circuit methods and devices.

Former Tesla employees have been hit with a lawsuit accusing them of engaging in an international campaign of industrial espionage and IP infringement.

CelLink filed a lawsuit at the US District Court for the Northern District of California on Friday against the founder of Manaflex, Robert Lane, and the firm’s director of engineering, Augusto Barton—both of whom previously worked for Elon Musk’s company.

The lawsuit alleges that the pair “used and abused their position of trust” during their time as Tesla employees after they were privy to business discussions with CelLink.

The pair allegedly stole trade secrets, copied proprietary technology, established competing manufacturing facilities abroad, and filed patent applications aimed at passing off CelLink's innovations as their own.

CelLink claims that Manaflex has misappropriated secrets, including innovative fabrication and manufacturing techniques related to battery optimisation and efficiency.

The suit also alleges infringement of the US patent number 11,116,070, titled Interconnect Circuit Methods and Devices issued September 7, 2021.

The patent covers methods of forming interconnect circuits used in many applications, including battery packs and solar arrays, vehicles, light fixtures, and other types of electrical circuits.

CelLink’s ‘innovative’ expertise targeted

CelLink specialises in the development of large, high-conductance flexible circuits for clean energy and automotive applications, and specifically, flexible circuits used in solar, LED, and battery industries.

The lawsuit alleged that Manaflex unlawfully exploited CelLink's proprietary technology to produce flexible printed circuits, undermining CelLink's “innovative market position”.

CelLink outlined the timeline of events in the complaint, including CelLink’s interactions with Tesla, discussions about proprietary technologies, and the departure of Lane and Barton from Tesla to establish Manaflex.

The complaint seeks various forms of relief, including injunctive measures to halt further infringement, damages to compensate for the alleged misconduct, and an award of attorneys' fees.

Timeline of events

The origins of the dispute trace back to 2014, when CelLink entered in negotiations with Tesla to discuss a partnership.

In a series of meetings between CelLink and Tesla, Lane sought technical details about CelLink's proprietary manufacturing methods.

In April 2016, CelLink informed Tesla that further collaboration would require a signed mutual non-disclosure (MNDA) agreement, which it agreed to.

The MNDA allegedly included confidentiality obligations for not only Tesla but also its employees, including Barton and Lane.

Over the subsequent months, as CelLink and Tesla explored new design opportunities, CelLink allegedly shared confidential and trade secret information with Tesla under the protection of the April 2016 MNDA.

New launch

Lane and Baron then left Tesla to launch Manaflex in August 2018, with the goal of producing flexible printed circuits in China.

In June 2020, Lane and Manaflex filed a US patent application (16/909,735) that allegedly disclosed some of CelLink's trade secrets shared with Lane under the April 2016 MNDA while he was at Tesla.

In December 2022, Barton joined Manaflex as its director of engineering.

During Barton's visit to CelLink's factory floor during his time at Tesla, he allegedly observed and accessed CelLink's manufacturing techniques (trade secrets), said the suit.

China location

In spring 2023, CelLink discovered that one of its US electric vehicle customers was contemplating transferring a flex circuit design to Manaflex for cost-effective manufacturing in China, with parts allegedly received from Manaflex in July 2023.

CelLink argues that Manaflex's products are based on misappropriated trade secrets, allowing Manaflex to avoid substantial R&D costs and offer products at lower prices.

The suit highlights that Manaflex claims to have a facility in Hawaii but CelLink believes most of its employees are based in China and Taiwan.

Additionally, CelLink alleged that Manaflex has exported these trade secrets to its manufacturing facilities in China, producing flexible circuits using the misappropriated knowledge and importing them to the US for sale to CelLink's customers.

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