Group14 Technologies Inc v. Nexeon Limited
2:22-cv-01354
W.D. Wash.Sep 18, 2024Background
- Group14 Technologies and Nexeon Limited are competitors in the silicon-carbon composite market for lithium-ion batteries.
- In 2016, the parties entered a Mutual Nondisclosure Agreement (NDA) and Materials Transfer Agreement to share information for potential business collaboration.
- Negotiations failed, the collaboration ended in 2018, and both parties went on to secure separate patents for similar technologies.
- Group14 filed suit in 2022, alleging trade secret misappropriation under federal and state law, unjust enrichment, and breach of contract; Nexeon counterclaimed for tortious interference.
- Multiple discovery disputes arose over whether Group14 had identified its trade secrets with sufficient particularity; the court previously found Group14’s identifications deficient.
- Nexeon moved for summary judgment, arguing time-bar, failure to identify any trade secret, preemption, and lack of evidence of breach or resulting unjust enrichment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| DTSA/UTSA Statute of Limitations | Claims timely; discovery rule delays accrual. | Claims accrued by November 8, 2018 (NDA termination), so time-barred. | Claims are time-barred; dismissed. |
| Trade Secret Identification | Has now identified trade secrets in new disclosures and expert reports. | Group14 never specifically identified any trade secrets; disclosures are vague/public. | No valid trade secret identified. |
| Unjust Enrichment | Should be allowed as alternative claim or damages theory. | Precluded—express contract (NDA) governs; claim is duplicative. | Preempted; dismissed. |
| Breach of Contract | Nexeon wrongfully disclosed/used/ transferred confidential materials. | No wrongful use/disclosure; transfers authorized or not pleaded; NDA expired. | No evidence of breach; dismissed. |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard for burden-shifting)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (evidence for summary judgment must create genuine fact issue)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (summary judgment where no rational trier of fact could rule for non-movant)
- Young v. Young, 164 Wn.2d 477 (2008) (unjust enrichment doctrine under Washington law)
- Precision Airmotive Corp. v. Rivera, 288 F. Supp. 2d 1151 (W.D. Wash. 2003) (discovery rule and burden of proof under Washington law)