CelLink Corp. v. Manaflex LLC

Background

CelLink sued Manaflex over alleged infringement of several patents and alleged misappropriation of trade secrets under the federal Defend Trade Secrets Act. CelLink’s amended complaint added Robert Lane and Augusto Barton as defendants to the trade-secret claim, added patent-infringement claims involving additional patents, and added three claims seeking correction of inventorship under 35 U.S.C. § 256.

The defendants moved under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not adequately state a legal claim. The motion challenged the correction-of-inventorship claims against Manaflex and the trade-secret claim against Lane and Barton.

Correction of Inventorship Claims

The court held that CelLink had not plausibly alleged that its identified inventors contributed to an invention claimed in any of Manaflex’s patents. A correction-of-inventorship claim requires facts supporting an inference that the plaintiff made more than an insignificant contribution to at least one patent claim and that there was some joint behavior, such as collaboration or work under common direction.

The amended complaint did not identify a particular patent claim or claim limitation to which CelLink’s inventors contributed. The court also found that allegations about Lane’s interest in CelLink’s manufacturing processes, CelLink’s disclosures to Tesla, and Barton’s observation of CelLink’s factory were not enough to show collaboration with CelLink’s inventors or use of their materials. The court therefore dismissed Counts VII–IX against Manaflex.

Trade-Secret Claim

The defendants argued that CelLink’s trade-secret claims against Lane and Barton were barred by the statute of limitations because Manaflex’s patent had issued and been published in November 2020. The court declined to dismiss the claims on that ground. CelLink alleged that it did not discover the alleged misappropriation until spring 2023, and the court found that allegation sufficient at the pleading stage to prevent the limitations bar from appearing conclusively on the face of the complaint.

The court separately found that CelLink had not adequately pleaded misappropriation by Barton. Although CelLink alleged that Barton knew about the trade secrets, it did not provide sufficient facts showing that he disclosed or used them. The court also found that CelLink had not adequately pleaded Lane’s knowledge of the trade secrets. The complaint repeatedly alleged that CelLink shared information with Tesla, but did not provide sufficient facts showing that Lane personally knew the information was a trade secret.

Disposition

The court granted the defendants’ motion to dismiss. The conclusion states that Count VI against Lane and Barton and Counts VII–IX against Manaflex were dismissed with leave to amend. It directed that Lane and Barton be terminated as defendants and allowed CelLink 21 days from the order to file an amended complaint.

The opinion contains an apparent count-number inconsistency: the motion, the background, and the discussion identify the trade-secret claim against Lane and Barton as Count IV, while the conclusion identifies it as Count VI. The court also set a case-management conference for May 13, 2025, and directed the parties to file a joint case-management statement by May 6, 2025.