Mobile Hot Spot OEM Sues Device-Makers, Sonim in Trade Secrets Case

Plaintiff Reliance, a wireless products OEM, retained defendants Teleepoch and Uni America to assist in the design, testing and manufacturing of certain Reliance products in Teleepoch’s Shenzhen, China, facility, said the complaint. Reliance’s products, sold to major wireless carriers in the U.S., were designed and tested to meet “strict technical requirements” and schedules set by the major wireless carriers, it said.

On information and belief, once Reliance received approval from wireless carriers that its products had met a carrier’s requirements, defendant Chuan Wang, chairman of Teleepoch and Uni, “would disclose to Sonim trade secret information, intellectual property, and other confidential information belonging to Reliance that Wang acquired through Teleepoch’s and Uni’s work for Reliance” -- despite operating under a nondisclosure agreement, said the complaint.

In 2022, Reliance released the Orbic Speed 5G mobile hot spot, which allegedly could handle a wireless carrier’s high-speed 5G network while operating at lower latency with higher capacity, said the complaint. Reliance employees in Teleepoch’s Shenzhen facility “have seen a Sonim device being designed and tested that appears to be a direct copy” of Reliance’s Orbic Speed 5G hot spot, the complaint alleged. In 2023, Sonim submitted to the FCC for approval a device that’s “nearly a carbon copy” of the Orbic hot spot, “including the same unique antenna placements, the same frequency bands, and the same integrated circuits that drive those frequencies,” it said.

Also last year, Reliance developed a technology that allows wireless communications products to operate with a single millimeter wave antenna module that met the technical specification requirements of major wireless carriers, the complaint said. Reliance’s “new invention significantly reduced the manufacturing costs incurred in producing wireless communication products” by using one antenna vs. the industry-standard two single-millimeter wave antenna design, it said. The plaintiff’s products incorporating the technology have not yet been released to the public, but its employees “in Teleepoch’s Shenzhen facility have seen Teleepoch implementing and testing this technology in Sonim products,” it alleged.

The complaint described Sonim as a “failing wireless communications manufacturer that was losing millions of dollars each year and heading for extinction until it got a significant equity investment from a group believed to be funded by Wang.” Soon thereafter, Sonim began developing products “using trade secrets, intellectual property, and other confidential and proprietary information stolen from Reliance,” it alleged. Sonim’s largest shareholder is AJP Holding Co., which owns about 50% of Sonim shares “and is controlled by the Wang family,” it said.

Reliance’s claims include DTSA violations, misappropriation of trade secrets, unfair competition, breach of contract and unjust enrichment. The company requests a judgment of damages to be proven at trial; exemplary damages of two times the amount of charges awarded under the DTSA; injunctive relief restraining the defendants from designing, manufacturing and selling products containing the plaintiff’s IP and trade secrets; and attorneys’ fees.