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WeRide Corp. v. Kun Huang

Citation: 379 F. Supp. 3d 834Docket: Case No. 5:18-cv-07233-EJD

Court: District Court, N.D. California; March 22, 2019; Federal District Court

Narrative Opinion Summary

This case involves WeRide Corp. and WeRide, Inc. pursuing legal action against Zhong Zhi Xing Technology Co. Ltd. (ZZX), AllRide.AI, Inc., and former employees, Wang and Huang, for trade secret misappropriation under the Defend Trade Secrets Act and California Uniform Trade Secrets Act, among other claims. The court addressed WeRide's Motion for Preliminary Injunction, highlighting the identification of trade secrets with reasonable particularity, focusing on functionalities and relevant file names. The court found WeRide likely to succeed against Huang, ZZX, and AllRide for misappropriation, noting Huang's breach of fiduciary duty by misappropriating confidential information and the unenforceability of non-solicitation clauses under California law. The court granted WeRide's request for injunctive relief, recognizing the irreparable harm from potential loss of market position and trade secret disclosure. While WeRide's claims against Wang for defamation and contract breach were less likely to succeed, the court approved expedited discovery to prevent further harm, balancing hardships in favor of WeRide and aligning with the public interest in protecting intellectual property.

Legal Issues Addressed

Breach of Contract under California Law

Application: The court found that WeRide's claims against Huang for breach of contract were likely to succeed, particularly regarding the misappropriation of confidential information.

Reasoning: In contrast, WeRide's claims against Huang for breach of contract are more promising.

Breach of Fiduciary Duty

Application: The court determined that Huang breached his fiduciary duty by misappropriating confidential information, a duty that extends beyond employment.

Reasoning: Conversely, the Court found that Huang likely breached his fiduciary duty by misappropriating confidential information, which is a continuing obligation beyond employment.

California Business and Professions Code § 16600

Application: The court concluded that non-solicitation provisions, like Paragraph 5 of Huang's agreement, are unenforceable under California law.

Reasoning: The Court finds WeRide's claim for breach of Paragraph 5 is unlikely to succeed as the clause is deemed void under California law (Cal. Bus. Prof. Code § 16600).

Defend Trade Secrets Act and California Uniform Trade Secrets Act

Application: The court analyzed claims of trade secret misappropriation under both federal and state laws, focusing on the identification and protection of WeRide's alleged trade secrets.

Reasoning: WeRide alleges trade secret misappropriation against all defendants under the federal Defend Trade Secrets Act (DTSA) and California Uniform Trade Secrets Act (CUTSA).

Evidentiary Standards for Preliminary Injunctions

Application: The court considered the weight of evidence presented by WeRide, despite objections over admissibility, under the standard practice for preliminary injunctions.

Reasoning: AllRide and ZZX object to the evidence presented by WeRide, asserting that district courts typically assign some weight to 'inadmissible evidence' to prevent irreparable harm.

Irreparable Harm and Injunctive Relief

Application: The court found that WeRide would suffer irreparable harm without an injunction, as the misappropriation of trade secrets could irreparably damage its market position.

Reasoning: The Court acknowledged that the potential loss of market position and trade secret disclosure constitutes irreparable harm.

Preliminary Injunction Standards

Application: WeRide met the preliminary injunction standard by demonstrating a likelihood of success on the merits, irreparable harm, and a balance of equities in its favor.

Reasoning: WeRide has met the preliminary injunction standard for these claims against Huang.

Reasonable Particularity in Trade Secret Identification

Application: The court found that WeRide sufficiently identified its trade secrets with reasonable particularity by naming specific functionalities and relevant files, satisfying the legal standard without needing to disclose specific lines of code.

Reasoning: The Court notes that WeRide has demonstrated reasonable particularity in identifying its trade secrets and does not evaluate the applicability of section 2019.210 under the DTSA.