Copy of the Complaint.

https://storage.courtlistener.com/recap/gov.uscourts.cand.47...

9. In the months before he left Apple, Mr. Tan met with OpenAI or its collaborators and discussed meetings with a key Apple supplier. He began emailing himself information about Apple’s suppliers and internal summaries of the consumer electronics industry. And today, when interviewing Apple employees for jobs at OpenAI, Mr. Tan uses Apple’s confidential information to gain access to even more insider knowledge. He has used an Apple internal project codename to ask, “What’s the plan[?]” for an unannounced Apple product. He has directed job candidates still working for Apple to bring “Actual parts” from Apple to their interviews for “show and tell” sessions in which he and his team at OpenAI can elicit still more Apple confidential information. These directions to bring Apple’s parts to OpenAI job interviews surprised at least one of the candidates, who commented that he “didn’t even know we could take those from the office.”

10. This is part of OpenAI’s strategy to extract Apple’s confidential information. OpenAI has been instructing Apple employees to bring “CAD/design artifacts” and “prototypes” to their interviews and to divulge details about their work such as “subsystem and component selection,” the “tools or methodologies you use for system integration, such as CAD software, simulation tools,” and “Vendor selection and communication/collaboration with vendors.”

11. OpenAI also instructs new hires on how to avoid scrutiny when they leave Apple. For example, Mr. Tan warns them not to tell Apple that they have taken jobs at OpenAI, so they can stay at Apple as long as they can. After his own departure, Mr. Tan improperly retained or obtained an internal Apple managers’ document marked “Need to Know” that describes security procedures for employee departures. Messages left on Apple-issued work devices show that Mr. Tan and his OpenAI colleagues have been sharing this document with new hires before they give notice to Apple of their departures, previewing Apple’s security protocols. Unsurprisingly, Apple’s investigation has found a pattern by employees who depart for OpenAI of taking steps to evade the security processes intended to protect Apple’s confidential information.