Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation
5:23-cv-05721
| N.D. Cal. | Aug 28, 2025Background
- Valeo, a supplier of automotive technology, accused NVIDIA of misappropriating its trade secrets related to parking assistance technology after a Valeo engineer, Mohammad Moniruzzaman, left Valeo for NVIDIA and allegedly took Valeo’s source code.
- Moniruzzaman was employed by NVIDIA to work on the Mercedes-Benz project, in which Valeo and NVIDIA were both technology suppliers.
- German authorities found that Moniruzzaman unlawfully took and retained Valeo documents; he was convicted in Germany for trade secrets theft. NVIDIA put him on leave and then terminated him, attempting to revert any contributions he made to their code.
- Valeo alleged that Moniruzzaman’s work at NVIDIA contaminated NVIDIA’s parking software with Valeo trade secrets, and NVIDIA’s cleanup was incomplete, leaving tainted code accessible.
- Valeo also pointed to another former engineer, Mohamed Shawki Elamir, hired by NVIDIA, who had Valeo files but denied using them at NVIDIA.
- Valeo brought trade secret misappropriation claims under the Defend Trade Secrets Act (DTSA) and California Uniform Trade Secrets Act (CUTSA); NVIDIA sought summary judgment on multiple grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Attribution of Moniruzzaman’s conduct | NVIDIA allowed use of Valeo’s trade secrets; circumstantial evidence supports inference | Moniruzzaman acted alone; NVIDIA not vicariously liable and reverted his code | Denied summary judgment; factual issues remain |
| Particularity of Trade Secret Identification | Valeo sufficiently identified trade secrets with reference to code, documents, figures | Valeo’s definitions are vague and overbroad | Denied summary judgment; factual issue |
| Use/misappropriation of specific trade secrets (3, 8, 4, 10) | NVIDIA used or derived from these via Moniruzzaman’s and (sometimes) Elamir’s conduct | NVIDIA reverted changes, or code/features are public domain or not matching Valeo’s | Denied summary judgment for 3, 8 (except Elamir’s 8), 4, and 10; factual issues |
| Use/misappropriation of specific trade secrets (9, 11, 12) | NVIDIA misappropriated through Moniruzzaman or Elamir | No evidence of NVIDIA’s acquisition/use; Elamir did not access/disclose after leaving Valeo | Granted summary judgment for 9, 11, 12 in NVIDIA’s favor |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (discussing burden and standard for summary judgment)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (defining what constitutes a material fact and the standard for summary judgment)
- T.W. Elec. Serv., Inc. v. Pac. Elec. Contractors Ass’n, 809 F.2d 626 (9th Cir. 1987) (court’s role at summary judgment)
- Imax Corp. v. Cinema Techs., Inc., 152 F.3d 1161 (9th Cir. 1998) (trade secret particularity requirement)
- Bourns, Inc. v. Raychem Corp., 331 F.3d 704 (9th Cir. 2003) (California rejection of inevitable disclosure doctrine)