Apple Inc. v. Chen Shi, Guangdong OPPO Mobile Communications Co., Ltd., et al. Complaint for Trade Secret Infringement and Breach of Contract

List of Key Chapter Headings

1. Introduction
2. Parties to the Action
3. Jurisdiction and Venue
4. Division Assignment
5. Background
6. 1. Apple's Trade Secret Technology is Critical to its Business and Success
7. 2. Apple Diligently Protects its Trade Secret Information
8. 3. The OPPO Defendants Recognized the Value of Apple's Trade Secrets
9. 4. The OPPO Defendants' Leadership Secretly Communicated with Chen Shi Regarding His Plan to Misappropriate Apple's Trade Secrets Before His Departure
10. 5. Chen Shi Transferred Apple's Trade Secrets for Himself and His New Employer, the OPPO Defendants, Before His Departure
11. First Cause of Action: Misappropriation of Trade Secrets Under the Defend Trade Secrets Act
12. Second Cause of Action: Breach of Contract
13. Prayer for Relief
14. Jury Trial Demand

Document Overview

This document is the formal Complaint filed by Apple Inc. on August 21, 2025, with the United States District Court for the Northern District of California, Case No. 5:25-CV-7105. The lawsuit is against former Apple employee Dr. Chen Shi and his new employers, Guangdong Oppo Mobile Telecommunications Corp., Ltd. ("OPPO") and InnoPeak Technology, Inc. ("InnoPeak", collectively the "OPPO Defendants"), alleging trade secret misappropriation and breach of contract. The Complaint elaborates in detail on the high sensitivity of the technologies involved, the alleged pattern of misconduct by the defendants, and the rigorous measures Apple has taken to protect its intellectual property.

The core allegations center on the actions of Dr. Chen Shi, former Apple Watch Sensor System Architect. The Complaint alleges that between April and June 2025, after accepting a job offer from the OPPO Defendants with a planned start date of June 30, Chen Shi concealed from his Apple colleagues the fact that he would be joining a direct competitor. During this period, he systematically scheduled numerous one-on-one meetings to gather information from Apple Watch technology team members regarding ongoing research and development on optical sensors, temperature sensors, electrocardiogram sensors, and more. More seriously, in the days just before his departure, Chen Shi downloaded a large volume of confidential documents containing core technical details from Apple's protected internal file systems and transferred them to a personal USB storage device, intended for use by the OPPO Defendants.

The Complaint provides a detailed evidentiary chain, including encrypted communication records between Chen Shi and individuals such as Dr. Zeng Zijing, Vice President of OPPO's Health Business. In these communications, Chen Shi explicitly stated he was "looking internally at various materials" and "doing many 1-on-1 meetings to collect as much information as possible," which he would later share with OPPO. OPPO personnel did not discourage this but instead encouraged it. The Complaint also notes that Chen Shi, in an attempt to cover his tracks, searched for keywords such as "how to completely wipe a MacBook" and "can anyone see if I opened a file on a shared drive."

In the legal argument section, the Complaint details the basis for the court's jurisdiction over the parties, including the defendants' substantial business presence in the Northern District of California, the forum selection and venue clauses in the confidentiality and intellectual property agreements signed by Chen Shi, and the close connection of the infringing acts and resulting harm to this district. The Complaint describes OPPO and InnoPeak as essentially interchangeable entities, jointly operating their "U.S. Research Center" in Silicon Valley, and directly benefiting from and competing within the same talent and technology ecosystem as Apple.

This document is not merely a legal filing but a deep case study on a core competitive element in the high-tech industry—the protection of trade secrets. It reveals the intense competition for talent and technology among multinational tech companies and the typical legal conflict patterns that arise. For defense researchers, policy analysts, and business intelligence professionals studying intellectual property law, corporate compliance, commercial espionage, Sino-U.S. technology competition, and cross-border legal enforcement, this Complaint provides first-hand material on the specific methods of alleged infringement, the effectiveness of corporate protective measures, and the construction of related legal claims. The health sensing technologies involved in the document, particularly technologies like electrocardiogram and blood oxygen saturation monitoring applied to wearable devices, are not only at the forefront of the consumer electronics field but are also relevant to broader strategic and technical issues such as biometric monitoring and personal health data security.