Wang v. Ehang Holdings Limited
- Beth Freeman
- 5:20-cv-00569
- U.S. District Court · Northern District of California
- 3
In Wang v. EHang, Judge Freeman kept Wang’s contract and wage claims alive but dismissed his unfair-competition claim with leave to amend.
Gary Wang’s breach-of-contract and unpaid-wages claims against EHang Holdings Limited and EHang Intelligent Technology remained pending. His unfair-competition claim was dismissed with leave to amend. The opinion also ruled that the defendants had waived their personal-jurisdiction defense.
What happened
In Wang v. EHang Holdings Limited, Gary Wang sued EHang Holdings Limited and other defendants over an employment-related dispute. The defendants asked the court to dismiss his breach-of-contract, unpaid-wages, and unfair-competition claims.
The court denied dismissal of the contract and unpaid-wages claims against EHang Intelligent Technology and EHang Holdings Limited. It concluded that Wang had adequately pleaded his employment and agency theories. The court also ruled that the defendants had waived their personal-jurisdiction defense by failing to raise it earlier.
Judge Beth Labson Freeman granted dismissal of Wang’s unfair-competition claim under California law because Wang had not shown that he lacked an adequate legal remedy. The court granted leave to amend and required Wang to file an amended complaint and a redlined version by February 4, 2021.
The detailed version
- Wang v. Ehang Holdings Limited · No. 5:20-cv-00569
- Beth Freeman
- Jan. 21, 2021
Background
Gary Wang brought four claims against EHang Holdings Limited, Guangzhou EHang Intelligent Technology Co., LTD., Huazhi Hu, Derrick Yifang Xiong, Shang-wen Hsiao, and Richard Jian Liu. The defendants moved to dismiss Wang’s breach-of-contract, unpaid-wages, and unfair-competition claims.
Personal Jurisdiction
The court rejected the defendants’ argument that it lacked personal jurisdiction. The defendants had not raised that defense in their earlier motion to dismiss, so the court held that they had waived it.
Contract and Unpaid-Wages Claims
The court held that Wang had adequately pleaded that EHang Intelligent Technology, the company identified in his contract, was the same company as Guangzhou EHang Intelligent Technology Co., Ltd. Because the defendants’ only challenge to the unpaid-wages claim was that Wang had not adequately alleged employment by that company, the court denied the motion to dismiss both the breach-of-contract and unpaid-wages claims against EHang Intelligent Technology.
The court also held that Wang had adequately pleaded both claims against EHang Holdings under an agency theory at this stage of the case. Wang alleged that executives of EHang Holdings, who were also executives of EHang Intelligent Technology, assured him that shares promised in his employment agreement were restricted stock units in EHang Holdings. The court therefore denied the motion to dismiss the contract and unpaid-wages claims against EHang Holdings.
Unfair-Competition Claim
The court granted the motion to dismiss Wang’s claim under California’s Unfair Competition Law. The court relied on a recent Ninth Circuit decision requiring a plaintiff seeking equitable restitution for past harm under that law to establish that the plaintiff lacks an adequate remedy at law. Wang acknowledged that he had not made that showing. The court granted leave to amend.
Disposition
The court denied the motion to dismiss the breach-of-contract and unpaid-wages claims and granted the motion to dismiss the unfair-competition claim with leave to amend. Wang was required to file an amended complaint and a redlined version by February 4, 2021.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.