Canoo Technologies, Inc. v. Harbinger Motors, Inc.
2:22-cv-09309
C.D. Cal.Feb 7, 2025Background
- Canoo Technologies, Inc. (Canoo) is an electric vehicle technology company that alleged that Harbinger Motors, Inc. and individual defendants misappropriated Canoo’s confidential technology and business plans for their own competitive advantage.
- Canoo filed the original lawsuit in December 2022, and then filed an amended complaint in March 2023, describing its proprietary "skateboard" platform technology and claiming substantial resources spent in its development.
- Canoo asserted that defendants used its technology and business information to develop a similar business model at an unusually rapid pace.
- On January 17, 2025, Canoo filed for Chapter 7 bankruptcy in Delaware, triggering the creation of a bankruptcy estate encompassing its pre-bankruptcy assets, including pre-petition legal claims.
- The court recognized that standing to prosecute pre-petition legal claims vests with the bankruptcy trustee, not Canoo, after the bankruptcy filing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Canoo retains standing to sue after filing for Chapter 7 bankruptcy | Canoo has not addressed in this order but generally may argue for exemption or abandonment from trustee. | Claims belong to the bankruptcy estate; only trustee has standing. | Canoo must show why the action should not be dismissed for lack of standing, as the claims now belong to the estate. |
Key Cases Cited
- Cusano v. Klein, 264 F.3d 936 (9th Cir. 2001) (pre-petition causes of action become bankruptcy estate assets)
- In re Raintree Healthcare Corp., 431 F.3d 685 (9th Cir. 2005) (bankruptcy estate includes all interests of the debtor).
- Rowland v. Novus Fin. Corp., 949 F. Supp. 1447 (D. Haw. 1996) (debtor must show claim is exempt or abandoned to have standing)
