Wireless Advanced Vehicle Electrification, LLC v. WiTricity Corporation
2:24-cv-00577
| D. Utah | Dec 18, 2024Background
- WAVE sued several former employees, WiTricity Corporation (a competitor), and WiTricity executives, alleging violations of employment agreements, theft of trade secrets, and related conduct.
- WAVE obtained a Temporary Restraining Order (TRO) barring 10 former employees from working for WiTricity for one year and 12 from using or disclosing WAVE’s confidential information.
- Defendants moved to stay the case and compel arbitration, arguing that employment agreements required arbitration of WAVE's claims.
- WAVE maintained that its claims sought only injunctive relief, which the employment agreements expressly allowed to be pursued in court.
- The parties agreed that the arbitration clauses permitted injunctive relief in court; there was no explicit dispute over the meaning of the arbitration clause.
- The TRO remains in effect, and the court was asked to decide whether to stay the proceedings for arbitration based on the submitted motions and briefing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Must the case be stayed for arbitration? | Only non-injunctive relief claims are arbitrable; seeking injunctive relief in court is allowed. | All claims must be arbitrated; WAVE's claim for only injunctive relief is illusory. | No stay required—no arbitrability dispute. |
| Does WAVE seek impermissible damages? | WAVE explicitly abandoned money damages claims against former employees in this court. | WAVE’s “no damages” position is untrue and meant to mislead the court. | Court accepts WAVE’s concession. |
| Authority to issue injunctive relief | Agreements allow for injunctive relief from the court. | Does not contest, focuses only on damages aspect. | Court can issue injunctive relief. |
| Public policy impact of a stay | Delaying litigation by compelling arbitration is unfair and undermines equity. | Not directly addressed. | Public policy supports denial of stay. |
Key Cases Cited
- Am. Exp. Co. v. Italian Colors Rest., 570 U.S. 228 (arbitration is a matter of contract and must be enforced per its terms)
- Dean Witter Reynolds, Inc. v. Byrd, 470 U.S. 213 (courts must stay litigation on issues agreed to be arbitrated)
- AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (Federal Arbitration Act policy favoring arbitration)
- Henry Schein, Inc. v. Archer & White Sales, Inc., 586 U.S. 63 (where arbitrability is clearly delegated to arbitrator, courts must submit even meritless disputes to arbitration)
- First Options of Chi., Inc. v. Kaplan, 514 U.S. 938 (arbitrability delegated to arbitrator only upon clear, unmistakable evidence)
- Belnap v. Iasis Healthcare, 844 F.3d 1272 (incorporating JAMS rules is clear evidence of intent to delegate arbitrability)