COMPLAINT

IN THE XXXX DISTRICT COURT
FOR THE WESTERN DISTRICT OF XXX

XXX, an inventor,
Plaintiff
vs.
XXXX
XXX
ELECTRONICS,
Defendants

Case No. _______________
Honorable: _____________

COMPLAINT

1. COMES NOW Plaintiff XXXX, with this complaint against the
Defendants, and alleges as follows:

INTRODUCTION

2. This is a trade secret misappropriation and IP Infringement dispute between
Plaintiff XXXX, an Inventor, and defendants XXXX,
XXXX CONNECTED SERVICES, AND SAMSUNG ELECTRONICS.

PARTIES

3. Plaintiff, XXXX (hereinafter “Plaintiff”), is an inventor and
businessman in XXXX area and resides in XXXX
4. Defendant XXXX (hereinafter “Mr. Thomson”) is an individual
of address [ENTER ADDRESS]. Upon information and belief, at all times material herein,
Aaron was a Senior Platform Director at Defendant Harman Connected Services.
5. Defendant, XXXX CONNECTED SERVICES (hereinafter “HCS”) is an
American subsidiary of Samsung Electronics through Harman International Industries, a wholly

XXXX

owned subsidiary of XXX electronics. The connected services division supplies software
services to the mobile communications industry. Upon information and belief, Defendant
Harman is based at XXX.
6. Defendant xxx ELECTRONICS (hereinafter “Samsung”) is a
multinational electronics corporation headquartered in Seoul, XXX. Samsung designs and
manufactures a wide variety of products, including cellular mobile devices.

JURISDICITON AND VENUE

7. This action arises under the patent laws of the XXXX, Title 35 of the
XXXX Code, 18 U.S. Code 1836, and under the Declaratory Judgment Act, 28 U.S.C. §
2201 et seq.
8. This Court has subject matter jurisdiction over this action under 28 U.S.C. §§
1331, 1338, and 2201(a).
9. Venue is proper in this district under 28 U.S.C. § 1391 as Plaintiff is subject to
personal jurisdiction in this state. Plaintiff lives within the jurisdiction of this Court. Besides, a
substantial part of the acts and omissions forming the basis of these claims occurred in the
Western District of Tennessee and arose from the actions or inactions of the Defendants.

FACTS

10. Plaintiff, an inventor, is the owner of a design patent (US D 904, 256 S) and a
utility patent pending, for Plaintiff’s invention called ADAS, an AI enabled dashcam. The
invention incorporates Artificial Intelligence (AI) image processing capabilities by facilitating
main server to vehicle communication; vehicle to vehicle communication; and receipt and
transmission of data with specific instructions including information about other approaching
vehicles and scanning registration plates of other vehicles.

XXX

11. Plaintiff was searching for an engineering firm w/software services and emailed
HCS, contacting Mr. Thompson, who was the Senior Platform Director, to inquire about
engineering and software services. Plaintiff explained he had a new and exciting invention, in
which he had a proto-type, held the said design patent and utility patent-pending, and wanted to
contract with HCS to build Plaintiff’s product.
12. On XXXX, at XXX, after accepting an email invite from Mr.
Thompson, the two parties engaged in a confidential phone call related to Plaintiff’s product, an
AI enabled dashcam. CCCC, a representative of a multi-billion dollar company stated
that the correct way to go about sharing information and getting started on a possible, future
collaborative effort, would be to work up a Non-Disclosure Agreement (NDA). Mr. Thompson
suggested being the architect of such document, since HCS/Samsung would be more familiar
with any project knowledge, pitfalls, and legal matters that may arise during the initial stages. He
would therefore word such a document accurately to protect both parties involved, but the proper
wording for the NDA would need to include word specific content related to the product as to
protect HCS/Samsung as well as Plaintiff.
13. Plaintiff had no reason to doubt Mr. Thompson’s sincerity and confidentially
shared the fact that the product has an issued design patent, and patent-pending status/utility, as
well as very specific proprietary design, technical and AI operations of the product not revealed
in the patent(s) so that the NDA approved by an HCS/Samsung employee would encompass all
the necessary details for protection of all parties involved. The NDA was promised within 48
hours and agreed upon by the next business day, which would have been on Monday, December
6, 2021. Plaintiff awaited the NDA, so he could review and sign the document. Two weeks
passed and Plaintiff, not overly concerned about the delay, wanted to cover an item or two that

CCC

were originally discussed and about the delayed NDA. For the said reasons, he placed a call to
Mr. Thompson to check in exactly two weeks after the original call on XXXX.
14. Plaintiff spoke to XXXX via cell at 1:59 p.m. on XXX to inquire
about the promised NDA and additional details of the upcoming project as there were questions
for both parties. Mr. Thompson stated the following, “I am on vacation, and the NDA is in the
works in the legal department at HCS.” Plaintiff then told him to enjoy his vacation, thinking that
XXXX had shown a genuine reason for the delay in the NDA. After this call, Mr.
Thompson would not return any calls/texts or emails placed by Plaintiff to Mr. Thompson. It was
now XXXX and no contact from HCS through any channel, so Plaintiff decided to try
another avenue as XXX approached.
15. Plaintiff then placed an email on XXXX
XXXX, Global Director of New Business Development for Harman, explaining the situation
with Mr. Thompson and if he knew of any other contact info or communication channels to
rectify this now very concerning matter. Plaintiff did include in the email to XXX, a
short synopsis of the issue, with the main point being the NDA and Plaintiff’s need for
engineering/software services with Harman. Henderson explained, he would, “see if he could
help”
16. At this point, Plaintiff knew that there was a possibility that all the information
shared with XXXX had fallen into the wrong hands and that an HCS/Samsung employee
may misappropriate the information, confidentially shared in the two conversations with Mr.
Thompson. Plaintiff called the customer service on 2-26-22 at 4:34 p.m. to no avail. However, he
went as far as to explain his situation and plight to a customer service contact that he reached at a

XXX

24 hour hotline, identified as XXXX. Plaintiff requestd any one from HCS/Samsung to
call back with any pertinent information.
17. On XXXX, Plaintiff received a call back from XXX
XXX, who identified himself as Client Director of Harman, and that he would be working on
this matter for Plaintiff and would get to the bottom of this after speaking with XXXX
Thompson to hear his side after multiple emails going unanswered. Ramachandran Narayan sent
an email XXX. telling Plaintiff, he had contacted Senior Platform Director, Aaron
Thompson, who stated he was going to reach out to Plaintiff, when the timing was right for an
opportunity. Plaintiff thought that was an odd statement: “when timing was right for a business
opportunity?”
18. Plaintiff was inquiring about services and needed pricing on the advertised
engineering and software services. Accordingly, Plaintiff was a potential customer. XXXX received an email from Ramachandran Narayan copying Plaintiff on XXXX at
5:51 p.m. stating he did speak with and urged Mr. Thompson to reach out directly to Plaintiff if
he saw an opportunity to engage in business. Again, there was no response from XXX.
19. Plaintiff was again trying to employ HCS/Samsung at this point, and thought this
was a sign that HCS/Samsung may be up to something with his shared information. At this point
all contact ceased from HCS/Samsung to Plaintiff. Plaintiff did, however, continue to visit
XXXX to look for any additional emails, phone numbers or mailing addresses that may
illicit a response or communication, to no avail. One of these visits to this website that occurred
in June did however reveal something very disturbing: An exact replica of Plaintiff’s product! It
was complete with literally every item discussed on the phone calls in XXXX, and
mimicked every AI operation listed in the patent pending page on the USPTO website.

XXXX

20. XXXX, Plaintiff felt that with the evidence discovered,
HCS/Samsung left no options other than a cease and desist letter sent directly to the company to
stop this travesty. The certified letter was received and signed for at HCS headquarters 30001
Cabot Drive, Novi, MI 48377 on XXXX
21. On XXXX, more trade secret misappropriation was uncovered and
IP infringement discovered at the below address on harman.com:
car.harman.com/solutions/smart-auto/connected-automotive-adas-dashcam.
22. Plaintiff was shocked that he was duped into divulging trade secrets and protected
IP information under the guise of information needing to be disclosed for the proper wording of a
Non-Disclosure agreement.
23. Plaintiff is therefore being harmed financially by an individual masquerading as a
legitimate employee of HCS/Samsung.

CLAIMS FOR RELIEF
COUNT 1

Trade Secret Misappropriation
24. The preceding paragraphs are fully incorporated herein.
25. Both Federal and Tennessee Trade Secret Laws govern Plaintiff’s
misappropriation claims.
26. Under federal law, 18 U.S. Code § 1836 (b) (1) provides that “an owner of a trade
secret that is misappropriated may bring a civil action under this subsection if the trade secret is
related to a product or service used in, or intended for use in, interstate or foreign commerce.”
27. The said law defines a trade secret as:
all forms and types of financial, business, scientific, technical, economic, or
engineering information, including patterns, plans, compilations, program

XXXX

devices, formulas, designs, prototypes, methods, techniques, processes,
procedures, programs, or codes, whether tangible or intangible, and whether or
how stored, compiled, or memorialized physically, electronically, graphically,
photographically, or in writing if— (A) the owner thereof has taken reasonable
measures to keep such information secret; and (B) the information derives
independent economic value, actual or potential, from not being generally
known to, and not being readily ascertainable through proper means by,
another person who can obtain economic value from the disclosure or use of
the information;
28. The said law further defines misappropriation as:
(A) acquisition of a trade secret of another by a person who knows or has
reason to know that the trade secret was acquired by improper means; or (B)
disclosure or use of a trade secret of another without express or implied consent
by a person who— (i) used improper means to acquire knowledge of the trade
secret; (ii) at the time of disclosure or use, knew or had reason to know that the
knowledge of the trade secret was— (I) derived from or through a person who
had used improper means to acquire the trade secret; (II) acquired under
circumstances giving rise to a duty to maintain the secrecy of the trade secret or
limit the use of the trade secret; or (III) derived from or through a person who
owed a duty to the person seeking relief to maintain the secrecy of the trade
secret or limit the use of the trade secret; or (iii) before a material change of the
position of the person, knew or had reason to know that— (I) the trade secret
was a trade secret; and (II) knowledge of the trade secret had been acquired by
accident or mistake;
29. TN Code § 47-25-1702 (2021) contains a similar definition of “trade secret” and
“misappropriation”, like the said federal law.
30. Plaintiff avers that all the required conditions for this cause of action have been
met.
31. HCS employees including and starting with XXXX fraudulently acquired
certain protected proprietary information as it relates to Plaintiff’s dashcam from a confidential
conversation initiated by XXXX via an email invite on Dec. 1, 2021 at 4:20 a.m.
32. XXXX followed up on that email invite after Plaintiff scheduled and
received a call on 12-3-21. On the approximately 26 minute phone call, Mr. Thompson duped
Plaintiff into divulging IP sensitive data and trade secret information relating to an AI enabled

XXX

dashcam that Plaintiff had invented with the promise of a protected document referred to as an
NDA- NON DISCLOSURE AGREEMENT. Plaintiff carefully gave the information that Mr.
Thompson angled for as he was searching for a firm that offered engineering services per the
HCS website information. Furthermore, it was understood that any information shared that day
on the 26 minute phone call and the additional call on 12-17-21 was confidential between two
potential collaborators until the NDA was signed by the two parties.
33. The NDA was never delivered by the HCS/Samsung employee as promised, but
the use of the plaintiff’s Intellectual Property and trade secret information were used by
HCS/Samsung immediately. Although HCS/Samsung had an elementary dashcam available to
consumers XXX, it was a very simple square camera with front/rear facing lens, IPhone or
Android applications, which are features present in all modern dashcams. However, the
Defendants appropriated Plaintiff’s sophisticated AI technology, as evidenced in their newly
released product, which is now available from HCS/Samsung w/misappropriated AI tech, along
with IP: US D 904,258 S directly copied from conversations between Plaintiff and Mr.
Thompson in XXXX.
34. Instead of following through with the NDA and steps to begin a new working
relationship, Senior Director Aaron Thompson accelerated its entry into the AI enabled dashcam
market by stealing Plaintiff’s trade secrets and infringing on Plaintiff’s Intellectual Property.
35. HCS/Samsung’s Thompson colluded with other HCS/Samsung department
employees.
36. HCS/Samsung, through its employees’ wrongful, willful and illegal conduct, has
succeeded in getting an unfair advantage on the competition and in the process, a clear violation
of DTSA, and Plaintiff’s rights.

XXXX

37. Plaintiff seeks damages in the form of lost profits and price erosion caused by
HCS/Samsung’s wrongful and accelerated entry into the market through its outright theft of
Plaintiff’s trade secrets. HCS/Samsung should further be ordered to disgorge any profits it
receives prior to the entry of the requested injunction from its sale and exportation of products
developed from its stolen trade secrets.
38. Plaintiff also seeks a finding that HCS/Samsung deliberately concealed the truth
willfully after Plaintiff confronting Defendants’ employees with the findings. The Defendants’
conduct was therefore oppressive, fraudulent, and malicious, and constitutes despicable conduct
in conscious disregard for Plaintiff’s Intellectual Property rights. Therefore, Plaintiff is entitled to
an award of exemplary or punitive damages.
39. Plaintiff is also entitled to an injunction compelling the Defendants to cease and
desist from using the Plaintiff’s trade secret in their product(s).
COUNT TWO

Infringement of U.S. Patent No. US D904,258 S
40. The preceding paragraphs are fully incorporated herein.
41. 35 U.S. Code § 281 provides that “[a] patentee shall have remedy by civil action
for infringement of his patent.”
42. Plaintiff has demonstrated above how his patent was infringed by the Defendants.
Notably, Plaintiff owns a design patent (US D 904, 256 S) and a utility patent pending, for
Plaintiff’s invention called ADAS, an AI enabled dashcam.
43. Defendants appropriated the said patent in their product “ADAS”. A description
of the product on Defendant Harman’s website reads: “… have the potential to remove human
error from the equation on the journey to zero-accident mobility. In addition, the evolution of

XXXX

more powerful cockpit architectures allows for the pre-integration of ADAS functionality in
Digital Cockpits.” The following description is followed by product specifications that show the
incorporation of AI in the dashcam features. For instance, the dashcam has connectivity features
and has cloud and edge software.
44. Although HCS/Samsung had an elementary dashcam available to consumers XXXX, it was a very simple square camera with front/rear facing lens, IPhone or Android
applications, which are features present in all modern dashcams. The Defendants only came up
with the said product after Plaintiff disclosed his trade secret to Mr. Thompson, which secret was
appropriated by the Defendants as evidenced.
45. Plaintiff is therefore entitled to damages adequate to compensate for the
infringement, together with interest and costs as fixed by the court.
46. Plaintiff also seeks a finding that HCS/Samsung deliberately concealed the truth
willfully after Plaintiff confronting Defendants’ employees with the findings. The Defendants’
conduct was therefore oppressive, fraudulent, and malicious, and constitutes despicable conduct
in conscious disregard for Plaintiff’s Intellectual Property rights. Therefore, Plaintiff is entitled to
an award of exemplary or punitive damages.
47. Plaintiff is also entitled to an injunction compelling the Defendants to cease and
desist from using the Plaintiff’s design patent in their product(s).
COUNT THREE

Breach of implied duty of good faith and fair dealing
48. The preceding paragraphs are fully incorporated herein.
49. First, a contractual relationship existed between Plaintiff and Defendants.
Specifically, the oral contract was entered on XXX, when Plaintiff and

XXXX
XXXX engaged in a confidential call upon which Plaintiff sought the correct way to go
about sharing information and getting started on a possible, future collaborative effort regarding
Plaintiff’s invention.
50. XXXX, acting as a representative and/or agent of Defendant Harman, and
Samsung, agreed to work up a Non-Disclosure Agreement and secure Plaintiff’s confidential
information.
51. Accordingly, part of the implied duties of the Defendant(s) included the duty to
ensure the secrecy of the disclosed information, and to avoid any unauthorized appropriation of
the information.
52. However, XXX disclosed the confidential information to the
Defendants, and colluded with the Defendants to appropriate the Plaintiff’s trade secret to
introduce a new product in the market.
53. As a result of the Defendant’s action, Plaintiff’s intellectual property rights have
been violated. Plaintiff has therefore lost economic benefit in and to his trade secrets. It follows;
Defendant should be held liable for the breach of the said implied duty of good faith and fair
dealing.
54. Plaintiff also seeks a finding that HCS/Samsung deliberately concealed the truth
willfully after Plaintiff confronting Defendants’ employees with the findings. The Defendants’
conduct was therefore oppressive, fraudulent, and malicious, and constitutes despicable conduct
in conscious disregard for Plaintiff’s Intellectual Property rights. Therefore, Plaintiff is entitled to
an award of exemplary or punitive damages.
55. Plaintiff is also entitled to an injunction compelling the Defendants to cease and
desist from using the Plaintiff’s design patent in their product(s).

XXXXX

COUNT 4
Declaratory Judgment
56. The preceding paragraphs are fully incorporated herein.
57. There now exists, between the parties hereto, a dispute and controversy to which
the Plaintiff and the Defendants are entitled to have a declaration of their rights and further relief
relating to the facts and circumstances as set forth in this action.
58. The dispute is whether the Defendants are liable for infringing on Plaintiff’s
intellectual property rights by appropriating Plaintiff’s trade secret, and using Plaintiff’s patent to
introduce a new product in the market, which product incorporates the said patent and/or trade
secret(s).
59. Plaintiff respectfully request this Honorable Court issue a declaratory judgment
declaring that the actions and/or inactions of the Defendants are blameworthy, and issue
appropriate remedies thereof. The declaratory judgment will also help Plaintiff ascertain his
rights in and to his trade secret and patent.

COUNT 5

Fraud- Intentional Misrepresentation
60. The preceding paragraphs are fully incorporated herein.
61. Defendant Mr. Thompson, as an agent of Defendant Harman and Samsung,
intentionally made false representations that he would prepare a Non-Disclosure Agreement to
secure Plaintiff’s trade secret, and that he would ensure confidentiality in the business
information shared to him by Plaintiff.
62. These representations made by Defendant Mr. Thompson were false.

XXXXX
63. XXXX knew that the representations were false when he made them, or
made the representations recklessly and without regard for their truth.
64. XXXX intended that Plaintiff relies on the representations.
65. Plaintiff reasonably relied on the representations.
66. All Defendants are liable for XXXX actions and/or inactions, under the
doctrine of respondeat superior, since XXX was acting as agent of XXXX, which in
turn is Samsung’s subsidiary.
67. As a result of the Defendant’s action, Plaintiff’s intellectual property rights have
been violated. Plaintiff has therefore lost economic benefit in and to his trade secrets. It follows;
Defendant should be held liable for the breach of the said implied duty of good faith and fair
dealing.
68. Plaintiff also seeks a finding that HCS/Samsung deliberately concealed the truth
willfully after Plaintiff confronting Defendants’ employees with the findings. The Defendants’
conduct was therefore oppressive, fraudulent, and malicious, and constitutes despicable conduct
in conscious disregard for Plaintiff’s Intellectual Property rights. Therefore, Plaintiff is entitled to
an award of exemplary or punitive damages.
69. Plaintiff is also entitled to an injunction compelling the Defendants to cease and
desist from using the Plaintiff’s design patent in their product(s).

COUNT 6
Fraud- Concealment

70. The preceding paragraphs are fully incorporated herein.
71. The Defendants intentionally failed to disclose material facts to Plaintiff. Notably,
Plaintiff made several attempts to follow up on the NDA that was promised by XXX.

XXXX
72. Instead of getting a clear answer, the individuals Plaintiff contacted acted
oblivious of the goings-on.
73. However, Plaintiff later found out that his trade secrets were already appropriated
by the Defendants into their latest product.
74. Had Plaintiff known earlier that XXX had already disclosed the trade
secrets to the Defendants, he would have made diligent efforts to prevent the Defendants from
appropriating the trade secrets and patent into their product.
75. As a result of the Defendant’s action, Plaintiff’s intellectual property rights have
been violated. Plaintiff has therefore lost economic benefit in and to his trade secrets. It follows;
Defendant should be held liable for the breach of the said implied duty of good faith and fair
dealing.
76. Plaintiff also seeks a finding that HCS/Samsung deliberately concealed the truth
willfully after Plaintiff confronting Defendants’ employees with the findings. The Defendants’
conduct was therefore oppressive, fraudulent, and malicious, and constitutes despicable conduct
in conscious disregard for Plaintiff’s Intellectual Property rights. Therefore, Plaintiff is entitled to
an award of exemplary or punitive damages.
77. Plaintiff is also entitled to an injunction compelling the Defendants to cease and
desist from using the Plaintiff’s design patent in their product(s).
COUNT SEVEN
Promissory Fraud

78. The preceding paragraphs are fully incorporated herein.
79. Defendant XXXX, as an agent of Defendant XXXX and Samsung,
intentionally made promises that he would prepare a Non-Disclosure Agreement to secure

XXXX
Plaintiff’s trade secret, and that he would ensure confidentiality in the business information
shared to him by Plaintiff.
80. The Defendant did not intend to perform the promises when he made it.
81. The Defendant intended the Plaintiff to rely on the promises, so that he may
disclose his trade secrets.
82. Plaintiff reasonably relied on the promises and proceeded to divulge his trade
secrets to the Defendant.
83. All Defendants are liable for Mr. Thompson’s actions and/or inactions, under the
doctrine of respondeat superior, since Mr. Thompson was acting as agent of Harman, which in
turn is XXX subsidiary.
84. As a result of the Defendant’s action, Plaintiff’s intellectual property rights have
been violated. Plaintiff has therefore lost economic benefit in and to his trade secrets. It follows;
Defendant should be held liable for the breach of the said implied duty of good faith and fair
dealing.
85. Plaintiff also seeks a finding that HCS/Samsung deliberately concealed the truth
willfully after Plaintiff confronting Defendants’ employees with the findings. The Defendants’
conduct was therefore oppressive, fraudulent, and malicious, and constitutes despicable conduct
in conscious disregard for Plaintiff’s Intellectual Property rights. Therefore, Plaintiff is entitled to
an award of exemplary or punitive damages.
86. Plaintiff is also entitled to an injunction compelling the Defendants to cease and
desist from using the Plaintiff’s design patent in their product(s).

XXXX

COUNT EIGHT
Negligent Misrepresentation
87. The preceding paragraphs are fully incorporated herein.
88. Defendant Mr. Thompson, as an agent of Defendant Harman and Samsung,
intentionally made false representations that he would prepare a Non-Disclosure Agreement to
secure Plaintiff’s trade secret, and that he would ensure confidentiality in the business
information shared to him by Plaintiff.
89. Although the Defendants may have believed that the representations were true,
they had no reasonable grounds for believing the representations were true when Mr. Thompson
made them.
90. Mr. Thompson intended that Plaintiff relies on the representations, to disclose his
trade secrets.
91. Plaintiff reasonably relied on the representations.
92. All Defendants are liable for XXXX actions and/or inactions, under the
doctrine of respondeat superior, since XXX was acting as agent of Harman, which in
turn is Samsung’s subsidiary.
93. As a result of the Defendant’s action, Plaintiff’s intellectual property rights have
been violated. Plaintiff has therefore lost economic benefit in and to his trade secrets. It follows;
Defendant should be held liable for the breach of the said implied duty of good faith and fair
dealing.
94. Plaintiff also seeks a finding that HCS/Samsung deliberately concealed the truth
willfully after Plaintiff confronting Defendants’ employees with the findings. The Defendants’
conduct was therefore oppressive, fraudulent, and malicious, and constitutes despicable conduct

XXXX
in conscious disregard for Plaintiff’s Intellectual Property rights. Therefore, Plaintiff is entitled to
an award of exemplary or punitive damages.
95. Plaintiff is also entitled to an injunction compelling the Defendants to cease and
desist from using the Plaintiff’s design patent in their product(s).
COUNT NINE
Breach of Contract

96. The preceding paragraphs are fully incorporated herein.
97. A contractual relationship existed between Plaintiff and Defendants. Specifically,
the oral contract was entered on XXXX., when Plaintiff and Mr.
Thompson engaged in a confidential call upon which Plaintiff sought the correct way to go about
sharing information and getting started on a possible, future collaborative effort regarding
Plaintiff’s invention.
98.XXXX, acting as a representative and/or agent of Defendant Harman, and
Samsung, agreed to work up a Non-Disclosure Agreement and secure Plaintiff’s confidential
information.
99. Accordingly, part of the duties of the Defendant(s) included the duty to ensure the
secrecy of the disclosed information, and to avoid any unauthorized appropriation of the
information.
100. However, XXXX disclosed the confidential information to the
Defendants, and colluded with the Defendants to appropriate the Plaintiff’s trade secret to
introduce a new product in the market.
101. As a result of the Defendant’s action, Plaintiff’s intellectual property rights have
been violated. Plaintiff has therefore lost economic benefit in and to his trade secrets. It follows;

XXXX
Defendant should be held liable for the breach of the said implied duty of good faith and fair
dealing.
102. Plaintiff also seeks a finding that HCS/Samsung deliberately concealed the truth
willfully after Plaintiff confronting Defendants’ employees with the findings. The Defendants’
conduct was therefore oppressive, fraudulent, and malicious, and constitutes despicable conduct
in conscious disregard for Plaintiff’s Intellectual Property rights. Therefore, Plaintiff is entitled to
an award of exemplary or punitive damages.
103. Plaintiff is also entitled to an injunction compelling the Defendants to cease and
desist from using the Plaintiff’s design patent in their product(s).
COUNT TEN
Tort of Another

104. The preceding paragraphs are fully incorporated herein.
105. As a result of the Defendants’ tortious conduct described herein, Plaintiff has
been forced to protect his interests by bringing this Federal Action against the Defendants,
wherein he seeks compensatory damages, punitive damages, injunctive relief to prevent the
Defendants from continuing to use his trade secrets, confidential information, and patent, and an
award of fees and costs.
106. In prosecuting this Federal Action, Plaintiff has incurred fees, costs, and other
expenses. Under the tort of another doctrine, Plaintiff is entitled to recover those expenditures
incurred in connection with the Federal Action from the Defendants.
PRAYER FOR RELIEF

WHEREFORE, the Plaintiff is entitled to damages from the Defendants, and he hereby
prays that judgment be entered in his favor and against the Defendants as follows:

XXXX

i. An Order that the Defendants have directly stolen, either literally or under the doctrine
of equivalents, one or more trade secrets from the Plaintiff;
ii. An Order for all compensatory damages to under applicable law, including lost profits,
but in no event less than a reasonable royalty;
iii. That Defendants be ordered to provide an accounting;
iv. That Plaintiff, as the prevailing party, shall recover from the Defendants all taxable
costs of court;
v. That Plaintiff shall recover from the Defendants all pre- and post-judgment interest on
the damage award, calculated to the highest interest rates allowed by law;
vi. That the Defendants and those acting in concert with the Defendants be preliminarily
and permanently enjoined from any further conduct based on the theft of trade secrets
of Plaintiff;
vii. That Defendants be preliminarily and permanently enjoined from engaging in any
marketing and sales efforts based on the theft of Plaintiff’s trade secrets, including
ceasing all marketing or sales efforts for the Harman smart/auto Vision ADAS
Dashcam;
viii. Declaratory judgment;
ix. Punitive damages;
x. Such other relief as the Court deems just and proper.
JURY DEMAND
Plaintiff demands a trial by jury on all clams so triable.

XXXX

Respectfully submitted:

Dated: __________

______________________________
XXX
Plaintiff, pro se

XXXX
CERTIFICATE OF SERVICE:

The undersigned hereby ce1iifies that the above and foregoing was served by regular U.S. Mail,
postage prepaid, on the Defendants:

[ENTER DEFENDANTS’ ADDRESS]

Dated: _____________

____________________________
XXXX
Plaintiff, pro se

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