Case 5:25-cv-07105-EKL Document 103 Filed 10/24/25 Page 1 of 23

1 Adam R. Alper (SBN: 196834) Annabel Hayoung Chang (SBN: 267261)

adam.alper@kirkland.com annabel@ahc-law.com
2 Laura Vartain Horn (SBN: 258485) 39116 Fremont Hub #1121
laura.vartain@kirkland.com Fremont, CA 94536
3 KIRKLAND & ELLIS LLP Telephone: (510) 404-8186
555 California Street
4 San Francisco, CA 94104 Attorney for Defendant Chen Shi
Telephone: (415) 439-1400
5 Robyn Carrico Crowther (SBN: 193840)
Michael W. De Vries (SBN: 211001) Rcrowther@steptoe.com
6 KIRKLAND & ELLIS LLP Sara Alwash Morse (SBN: 347086)
695 Town Center Drive smorse@steptoe.com
7 Costa Mesa, CA 92626 STEPTOE LLP
Telephone: (714) 982-9922 633 West Fifth Street, Suite 1900
8 Los Angeles, CA 90017
Leslie M. Schmidt (admitted pro hac vice) Telephone: (213) 439-9428
9 leslie.schmidt@kirkland.com
KIRKLAND & ELLIS LLP Attorneys for Defendant Guangdong Oppo
10 601 Lexington Avenue Mobile Telecommunications Corp., Ltd.
New York, NY 10022-4611
11 Telephone: (212) 446-4800 Randall Evan Kay (SBN: 149369)
rekay@jonesday.com
12 Maria M. Beltran (SBN: 327237) JONES DAY
maria.beltran@kirkland.com 4655 Executive Drive, Suite 1500
13 KIRKLAND & ELLIS LLP San Diego, CA 92121
2049 Century Park East, Telephone: (858) 314-1139
14 Suite 3700
Los Angeles, CA 90067 Attorneys for Defendant InnoPeak Technology,
15 Telephone: (310) 552-4200 Inc.
16 Attorneys for Plaintiff Apple Inc. [Additional counsel in signature page]
17
UNITED STATES DISTRICT COURT
18
NORTHERN DISTRICT OF CALIFORNIA
19
SAN JOSE DIVISION
20
APPLE INC., CASE NO. 5:25-CV-07105-EKL
21
Plaintiff, JOINT STATUS REPORT
22
v. PUBLIC VERSION – REDACTED
23
CHEN SHI, GUANGDONG OPPO MOBILE
24 TELECOMMUNICATIONS CORP., LTD., and
INNOPEAK TECHNOLOGY, INC.,
25
Defendants.
26

27

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1 Plaintiff Apple Inc. (“Apple”), Defendant Chen Shi (“Dr. Shi”), Defendant Guangdong Oppo
2 Mobile Telecommunications Corp., Ltd. (“OPPO”), and Defendant InnoPeak Technology, Inc.
3 (“InnoPeak”), by and through their respective undersigned counsel, hereby submit the following joint
4 status report pursuant to the Court’s scheduling orders. Dkts. 41, 90. By way of background, in its August
5 29, 2025 Minute Order, the Court requested that “the parties shall meet and confer regarding whether
6 preliminary injunction proceedings are necessary, and if so, their scope.” The parties provide their
7 positions on those issues, below.
8 I. APPLE’S STATEMENT
9 Discovery has confirmed that a preliminary injunction beyond the interim measures is necessary
10 in this case, and Apple therefore maintains its request for preliminary-injunction proceedings. When
11 Apple filed its complaint and sought a TRO, Apple’s internal investigation had already revealed that Dr.
12 Shi gathered Apple’s trade-secret information prior to his departure from Apple and intended to use that
13 information at OPPO and InnoPeak (the “OPPO Defendants”) to develop competing products, all with the
14 OPPO Defendants’ knowledge and encouragement. Defendants’ misappropriation included Dr. Shi’s
15 download of trade secret documents to a personal USB drive. Dkt. 1 at 20-21. He also conducted dozens
16 of one-on-one meetings under false pretenses with members of Apple’s technical team to gather details
17 about Apple’s ongoing and future research and development of wearable devices, including optical,
18 temperature, and ECG sensor technologies. Dkt. 12 at 6-7. The OPPO Defendants not only hired Dr. Shi
19 because of his access to this information, they encouraged him to take it. Dkt. 12 at 12-15. As Dr. Shi
20 expressed to the OPPO Defendants during his hiring discussions, he would make his “best effort to learn
21 as much…as possible” and “collect as much information as possible” about Apple’s trade secrets prior to
22 his departure, and “will share with you all later,” (“you all” referring to the OPPO Defendants). Id.
23 OPPO’s Vice President and Head of OPPO Health, Dr. Zijeng Zeng, expressly approved this conduct. Id.
24 To address Apple’s TRO application, the parties agreed to interim measures and the Court ordered
25 Defendants to provide expedited discovery in connection with Apple’s forthcoming preliminary injunction
26 motion. Dkt. 28.
27

28

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1 While OPPO’s production remains largely incomplete, 1 the limited documents Defendants have
2 produced thus far show that (1) the OPPO Defendants have actively participated in the theft of Apple’s
3 trade secrets, including soliciting from Dr. Shi highly sensitive information about the design of current
4 and future Apple sensor technologies upon his arrival at the OPPO Defendants; (2) hundreds of employees
5 at the OPPO Defendants have now been exposed to Apple’s proprietary and confidential information; (3)
6 the OPPO Defendants have been exposed to Apple proprietary and confidential information, contrary to
7 the OPPO Defendants’ claims; and (4) the OPPO Defendants have not satisfied their obligations under
8 the court-ordered interim measures, and additional measures in the form of a near-term preliminary
9 injunction are urgently required to put a stop to Defendants’ dissemination and use of Apple’s trade
10 secrets, and to prevent further irreparable harm to Apple.
11 More specifically, discovery has revealed that shortly after joining the OPPO Defendants, Dr.
12 Shi—who the OPPO Defendants claim is an employee of InnoPeak—gave a presentation on August 1 to
13 hundreds of OPPO employees. During that presentation, Dr. Shi disclosed trade-secret information
14 concerning Apple’s sensor technology, including Apple’s development of its technology and future plans.
15 Dr. Shi’s illicit disclosures were blatant. For example, certain slides from Dr. Shi’s presentation appear
16 to contain images copied directly from the Apple trade secret materials he misappropriated. The OPPO
17 Defendants not only encouraged these disclosures; they touted them, advertising Dr. Shi’s presentation to
18 their personnel as one at which they would learn about “how Apple’s sensors are developed” from a
19 “former Apple technical director”:
20

21

22

23

24

25

26

27 1
OPPO has produced 214 documents to date, but contends it will substantially complete its
28 production by October 24, 2025.

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10

11

12

13

14

15

16

17

18

19 OPPO_0000511. This continued at the presentation as well. . For example, employees interactively asked

20 Dr. Shi to provide additional confidential details about Apple’s trade-secret technologies. Those questions

21 included “Could you talk a bit about how the iPhone handles light sensing and color temperature

22 algorithms?”; “Can an ultrasonic proximity solution be made using an elliptical design? How can we

23 bypass the patent?”; and “I’d like to ask, do sensors like microphones have a noticeable impact on

24 improving algorithm performance, like in Apple before.” OPPO_0000783 (questions submitted on

25 livestream). To ensure no details were missed, Dr. Shi’s slide presentation was made available to anyone

26 at OPPO for downloading for more than three weeks (at least).

27 The limited evidence provided to date also reveals Defendants’ attempts to obscure their

28 misconduct, confirming that Defendants knew what they were doing was wrong. For instance, Dr. Shi’s

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1 presentation initially referred explicitly to Apple by name in its title and in Defendants’ promotional
2 materials. But, in an apparent attempt to superficially hide that the presentation included Apple’s
3 confidential information, Dr. Shi subsequently revised the title to remove explicit references to “Apple”
4 and instructed his colleagues to “kindly avoid mentioning that I am talking about Apple’s technologies.”
5 OPPO_000781. Aside from these surface-level changes, however, Dr. Shi did not remove any of the
6 underlying trade-secret information from the presentation. In fact, he added additional Apple trade-secret
7 information (again without naming Apple) to the final version he presented. And no one tried to stop Dr.
8 Shi from making these disclosures. To the contrary, as discussed above, the OPPO Defendants eagerly
9 welcomed it. OPPO_0000781 (Chen Lin: “[Sly smile [emoji]] Welcome Dr. Shi to frequently join HiO
10 for sharing, develop courses, and become our company-level instructor.”).
11 Dr. Shi’s August 1, 2025 presentation is just one example of Defendants’ misdeeds: Dr. Shi also
12 gave at least one other presentation to OPPO employees that likewise disclosed Apple’s trade-secret
13 information regarding Apple’s sensor technology. And there could be many more. To date, OPPO has
14 not yet produced documents responsive to Apple’s search terms, which are directed to the content of the
15 trade-secret information Dr. Shi misappropriated. Similarly, OPPO has not provided complete forensic
16 reports of the devices in its possession, including Dr. Zeng’s devices. Even with respect to the August 1,
17 2025 presentation, the OPPO Defendants have not explained how Dr. Shi prepared that presentation;
18 identified who he discussed it with; provided forensic data relating to its creation and distribution; or
19 identified any non-Apple materials used to create the presentation.
20 Critically, despite these obvious misuses of Apple’s trade secrets, Defendants’ interrogatory
21 responses fail to acknowledge them. In fact, the OPPO Defendants contend, to this day, that they have
22 not been exposed to any Apple confidential information. OPPO’s 9/25/25 Response to Apple’s
23 Interrogatory No. 4 (claiming that the August 1, 2025 presentation “did not include any information that
24 was confidential or proprietary to Apple or not generally known to the industry” and contending that no
25 other disclosures or dissemination of Apple confidential information exist). Moreover, while the OPPO
26 Defendants purport to have satisfied their requirements under the Court’s interim measures, that cannot
27 be the case. For example, the OPPO Defendants have not yet conducted a reasonable search for “files or
28 materials derived from, concerning or referencing” the files listed in Ex. A to the interim measures order

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1 (Dkt. 28), e.g., applying Apple’s search terms as Apple has requested, or searching for materials derived
2 from Dr. Shi’s presentations. Nor have they quarantined such files. Id.. Rather, they simply deny that
3 any such Apple confidential information has been disseminated in the first place (a position which is
4 obviously wrong based on the evidence produced to date).
5 As such, further, specific injunctive relief is necessary to put a stop to the ongoing dissemination
6 and use of Apple’s trade-secret information.
7 Such additional injunctive relief should at least require:
8 • That the OPPO Defendants identify and quarantine the employees that have been exposed to Apple’s
trade secrets from working on any competitive technologies;
9
• That the OPPO Defendants implement cleanroom procedures for development of any technology
10 related to Apple’s trade secrets, including that any development work performed by those who were
exposed to Apple’s trade secrets be quarantined, and further work be conducted by employees who
11 have not been exposed to Apple’s trade secrets;
12 • That Apple have the ability to audit the OPPO Defendants’ data sources to ensure that Apple’s trade
secrets have been quarantined and are not being used or further disclosed, including by reviewing the
13 OPPO Defendants’ databases and document repositories and the mailboxes of relevant employees and
any related forensic information; and
14
• Additional document and forensic discovery to identify the full scope of the OPPO Defendants’
15 dissemination and use of Apple’s trade secret information to date, and an opportunity to amend the
preliminary injunction based on such additional discovery.
16
As for Dr. Shi, additional injunctive relief should at least include that Dr. Shi will not disclose or
17

18 use any Apple trade secrets. In addition, as an employee of the OPPO Defendants, Dr. Shi would be subject

19 to the relief sought against OPPO/Innopeak. Apple should also have the opportunity to take additional

20 document and forensic discovery and to amend the preliminary injunction based on such additional
21
discovery.
22
Defendants’ discovery is not yet complete. For example, additional depositions will occur next
23
week and the OPPO Defendants are still working to produce additional documents and forensic reports.
24
This additional discovery will further inform the scope of relief Apple seeks, and Apple will further tailor
25

26 its requests for injunctive relief in its preliminary injunction briefing as needed.

27 With respect to OPPO, as set forth above, preliminary injunction proceedings are clearly
28 necessary. Although OPPO contends that the August 1 presentation does not contain Apple trade secrets,

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1 that is incorrect, and Apple’s trade secret disclosure and interrogatory responses directly compare the
2 presentations to Apple trade secret documents and Defendants’ copying is clear. Moreover, OPPO has no
3
response for the second presentation containing Apple confidential information at all. OPPO’s claims of
4
having performed an extensive review of documents is belied by the fact that it has only produced 214
5
documents thus far, none of which are for Apple’s search terms. To obtain those documents, Apple was
6

7 forced to file a motion to compel with Judge DeMarchi.

8 OPPO’s assertions that Apple has not produced its trade secret documents is incorrect. While

9 Apple did produce them today (October 23), OPPO has been in possession of Apple’s trade secret
10
disclosure describing those documents since at least September 11, 2025. Moreover, OPPO’s opposition
11
brief to Apple’s forthcoming preliminary injunction motion is not due for four weeks. OPPO’s other
12
assertions concerning Apple’s discovery responses are likewise incorrect; Apple has been diligently
13
attempting to satisfy OPPO’s requests, despite their unreasonable breadth.
14

15 OPPO’s assertion that Apple has made an “eleventh hour disclosure of additional relief it will

16 seek” is also incorrect. In conferring over statement, OPPO requested that Apple provide a summary of
17 the relief it plans to seek. While discovery is still occurring (and the vast majority of OPPO’s document
18
production has yet to be produced, and most depositions will not occur until next week), Apple provided
19
an explanation of additional measures that should be put in place to prevent further dissemination of its
20
trade secrets and stop the irreparable harm Defendants’ actions have caused. OPPO’s assertion that those
21

22 disclosures may require a delay in these proceedings is without merit.

23 With respect to InnoPeak, it contends that its “two months of extensive investigation” have not

24 turned up any evidence of Apple’s trade secrets and as such, additional injunctive measures are
25 unnecessary. Not so. As Innopeak’s 30(b)(6) witness confirmed at his deposition yesterday (October 22),
26

27

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2 Rough Tr. (InnoPeak) at 179:1-180:14. And while InnoPeak claims it has produced all
3
information it possesses relevant to the theft, it did not disclose those facts in any interrogatory response,
4
and to this day, has not provided the forensic records related to Dr. Shi’s use of the Seagate USB.
5
InnoPeak’s reason for this is telling: according to InnoPeak’s counsel, InnoPeak “do[es]n’t believe its
6

7 responsive to any RFPs.” Rough Tr. (InnoPeak) at 187:5-10. But of course such information is

8 responsive: it is direct evidence of the dissemination of Apple’s trade secrets at InnoPeak, and was

9 specifically requested in Apple’s discovery requests that require InnoPeak to “identify all Devices,
10
including hard drives…that have been or are in Your possession, custody, or control that Dr. Shi has or
11
had access to.” Apple’s Interrogatory No. 1 to InnoPeak.
12
And even beyond that, InnoPeak’s position in this statement fails to reveal that it just produced
13
(this week) file listings and web browser history for Dr. Shi’s InnoPeak work laptops that show Dr. Shi’s
14

15 work on various versions of his August 1 presentation, as well as contemporaneous work on other

16 documents relating to sensor technology. And, InnoPeak’s 30(b)(6) witness confirmed that there is still
17 more forensic information about Dr. Shi’s InnoPeak laptops available to InnoPeak that InnoPeak has yet
18
to provide. Once again, InnoPeak refuses to provide these files, or information about how they were
19
created or shared with others, claiming that this highly relevant information is not responsive to any Apple
20
discovery requests.
21

22 InnoPeak also fails to reveal that at least Jason Liao (who purports to be on the leadership team at

23 InnoPeak and who was one of the senior executives who recruited Dr. Shi from Apple) and Jie Hawes

24 (an InnoPeak employee who purportedly reported to Dr. Shi), attended Dr. Shi’s August 1 presentation
25 that disclosed Apple trade secrets. Mr. Liao was directly involved in Dr. Shi’s hiring, and Dr. Hawes
26
worked on Dr. Shi’s team at InnoPeak. Once again, InnoPeak buries its head in the sand:
27

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1 Rough Tr. (InnoPeak) at 114:5-12. That assertion is flat wrong, as clearly shown by the
2 presentation itself, and Dr. Shi’s (and other employees’ statements) surrounding it. OPPO_0000626.
3
Meanwhile, InnoPeak has provided no meaningful discovery as to what Drs. Liao and Hawes did with the
4
information they learned from the presentation, or provided a basis to believe they have investigated which
5
other InnoPeak employees witnessed (or downloaded) the presentation.
6

7 And while InnoPeak claims to have acted responsibly, the evidence shows otherwise: rather than

8 fully quarantining Dr. Shi when it purports to have become aware of the theft, InnoPeak provided him

9 with yet another laptop, which allowed Dr. Shi to access OPPO and InnoPeak’s networks and document
10
repositories. For at least 24 hours, Dr. Shi had the ability to access OPPO and InnoPeak documents, delete
11
or modify them to further conceal the theft, and otherwise surreptitiously carry out the misappropriation.
12
Moreover,
13
. Rough Tr. (InnoPeak) at 229:6-12. And at an even higher
14

15 level, InnoPeak’s attempt to distance itself from OPPO is also inconsistent with the facts. While InnoPeak

16 may be a separate company, its employees appear to have access to all of OPPO’s resources, and perform
17 overlapping work (including work on the types of sensor technologies at issue). Indeed, while Dr. Liao
18
purports to be on the leadership team at InnoPeak, he is listed as the President of the “OPPO Research
19
Institute,” and gained open access to Dr. Shi’s August 1 presentation to hundreds of OPPO employees.
20
In sum, while InnoPeak is currently withholding critical evidence relating to its role in the theft, it
21

22 undeniably is involved. InnoPeak’s refusal to acknowledge that it has been exposed to Apple’s trade

23 secrets raises significant concerns and confirms the need for additional injunctive measures to be applied

24 to InnoPeak as well as OPPO.

25 While InnoPeak takes issue with Apple’s responses to InnoPeak’s discovery requests, those
26
requests were made over a month after Apple’s discovery requests, and Apple provided its responses
27
earlier than it was required to. In conjunction with Apple’s discovery responses, Apple has already began
28

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1 producing documents and has produced many of its trade-secret documents. Apple further expects to
2 produce many more documents over the coming days.
3
Discovery with respect to Dr. Shi is ongoing. Dr. Shi’s deposition will take place next week, and
4
Apple expects to receive the forensic reports pursuant to the forensic protocol (Dkt. 79) next week, along
5
with documents that were collected from Dr. Shi's personal devices and cloud accounts. Apple disagrees
6

7 with Dr. Shi’s recounting of the parties’ meet and confer process, and this is the first time that Dr. Shi

8 advised that he is experiencing health issues that may interfere with the deposition. Apple will confer

9 further with Dr. Shi on his deposition and raise issues if necessary. Nonetheless, Dr. Shi agrees that the
10
preliminary injunction should go forward on the existing schedule.
11
II. DR. SHI’S STATEMENT
12

13 Following this Court’s order on August 29, 2025 (Dkt. No. 41), Dr. Shi has cooperated with
14
Apple’s expedited discovery requests at every turn. In fact, in the parties’ September 12, 2025 Joint Status
15
Report (the “JSR”), Apple represented to the Court that Dr. Shi “has worked cooperatively with Apple to
16
advance discovery . . . including to turnover for inspection the devices that remain in Dr. Shi’s possession.”
17
Dkt. No. 59.
18

19 Not only has Dr. Shi turned over all physical devices within his possession, custody, and control
20 for Apple’s forensic inspection, he even allowed Apple to access his non-physical devices (i.e., cloud
21 storage and email accounts) for forensic inspection.
22 Apple further represented to the Court in the JSR that “Dr. Shi has also agreed to sit for a limited
23 deposition provided there is an agreement on scope, and Apple and Dr. Shi are working together to
24 schedule that deposition and further confer regarding any limitations on the deposition” (emphasis
25 added).
26 Over the course of multiple meet and confers the parties discussed the topics and questions that
27 would be suitable for Dr. Shi’s limited deposition, and Apple agreed to memorialize the agreed-upon
28

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1 topics in an email. Based on Apple’s representations, Dr. Shi agreed to stipulate that the deadline for him
2 to sit for deposition should be extended from October 23, 2025, to October 31, 2025.
3 However, on the morning of October 23, 2025, Apple simply informed Dr. Shi that “the best path
4 forward is for the parties to proceed with Dr. Shi’s deposition” and Dr. Shi’s counsel could just object
5 and/or instruct him not to answer any questions that were considered outside the scope of what he would
6 be willing to testify to.
7 What Apple is now belatedly proposing is no different than any other deposition, where the
8 deposing counsel is free to ask any question they choose and the defending counsel may object or, when
9 appropriate, instruct their client not to answer. Apple’s current position does not comport with its earlier
10 representations to the Court that there would be a limited deposition with an agreed-upon scope. Nor is it
11 what Dr. Shi relied on when representing to the Court in the JSR that a stay on discovery would not be
12 needed “if there is agreement on a limited scope deposition that will not require Dr. Shi to invoke his Fifth
13 Amendment privilege.”
14 More critically, Dr. Shi has recently been diagnosed with a medical condition that is likely to be
15 significantly exacerbated by participation in a lengthy, high-stress, and adversarial proceeding such as the
16 deposition sought by Apple.
17 Dr. Shi therefore plans to bring an administrative motion to extend his deposition deadline to
18 ensure he can (1) recover sufficiently to participate meaningfully in his defense; and (2) assess whether a
19 protective order is necessary to limit or stay his deposition.
20 With respect to whether preliminary injunctive relief against Dr. Shi is warranted, it is not. Apple
21 has no basis for such extraordinary relief. Dr. Shi has cooperated in good faith with Apple’s extensive
22 discovery demands, producing substantial documents and responses, and he remains on administrative
23 leave without access to InnoPeak or OPPO’s systems or facilities.
24 However, even if Apple were to proceed with preliminary injunction briefing, that process can
25 continue on the existing schedule. A postponement or stay of Dr. Shi’s deposition should not affect that
26 schedule, as Apple already possesses the discovery necessary to prepare its briefing.
27

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1 III. OPPO’S STATEMENT

2 After a comprehensive search of the systems to which Dr. Shi had access and Dr. Zeng’s devices,
3
a broader search for documents that might have been derived from something Dr. Shi retained from Apple,
4
and a comprehensive investigation, there is no indication that OPPO received any Apple trade secret
5
information from Dr. Shi. Working with its third-party vendor, Ankura Consulting (“Ankura”), OPPO
6

7 collected hundreds of thousands of documents, searched them for hundreds of terms identified by

8 Defendants and Apple, and reviewed tens of thousands of documents that hit on those terms. This search

9 revealed that only two of the files Apple claims Dr. Shi “exfiltrated” from Apple appeared on any of
10
OPPO’s systems. One was Dr. Shi’s “self-introduction,” which described his work history, and the other
11
related to work Dr. Shi had done as part of his Ph.D. research. Those are not Apple’s trade secrets.
12
In its interrogatory response setting forth acts of alleged misappropriation, Apple devotes several
13
pages to two presentations that Dr. Shi provided to OPPO: one is an August 1, 2025 presentation of high-
14

15 level engineering and sensor design principles (the “OTalk Presentation”) and the second is a discussion

16 of wrist-temperature sensor algorithm and testing methodologies (the “Wrist Temperature Sensor
17 Presentation”). But neither presentation contains any disclosure of Apple confidential information.
18
Instead, the OTalk Presentation generally relates to the discussion of general engineering principles
19
regarding certain health sensors and other widely-known technologies. Similarly, the Wrist Temperature
20
Sensor Presentation discusses generalized application of well-known thermodynamic principles and using
21

22 commercially-available, off-the-shelf products to improve the functions of the temperature sensors.

23 Neither of these presentations contain any disclosures of Apple’s trade secrets.

24 OPPO asked Apple to provide copies of the files it claims Dr. Shi took so that OPPO would be
25 able to search for them and any materials that might be derived from them. Apple has refused and to this
26

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1 day still has not produced them. 2 It’s clear that Apple does not want OPPO to be able to search for those
2 documents. Apple wants, instead, an inference that OPPO has them and is hiding them which is simply
3
not true.
4
Having found no indication that OPPO received Apple trade secret information, OPPO submits
5
that there is no basis for Apple to seek any preliminary injunction, and that the Interim Measures related
6

7 to OPPO should now be dissolved. The search is complete and there is no “Apple property” to be further

8 quarantined or returned.

9 A. OPPO Provided Complete Responses to Apple’s Expedited Discovery Requests

10 Per the Court’s August 29 Order, OPPO served responses to Apple’s Interrogatories and Requests
11
for Production on September 25. OPPO produced documents on October 9 and is preparing a supplemental
12
production for October 24 after which its production in response to Apple’s First Set of Requests for
13
Production will be complete. OPPO has served a privilege log and a log of documents that were withheld
14

15 or redacted by OPPO’s Chinese counsel on the basis of Chinese law.

16 OPPO incurred the cost and effort of collecting more than 3,000,000 documents and processed

17 more than 1,500,000 to be searched. After running hundreds of search terms, OPPO reviewed more than
18 47,000 documents to determine whether they were responsive. OPPO also engaged Ankura to conduct
19
forensic reviews of Dr. Zeng’s devices and provided reports to Apple of that analysis with the information
20
Apple requested.
21
Although OPPO located only two of the files that Apple claims Dr. Shi stole from Apple on its
22

23 systems and neither of them contained any Apple information at all, OPPO will have produced more than

24 1,200 documents in response to Apple’s RFPs including documents referencing Dr. Shi, about his

25 recruitment and onboarding, and reflecting the work he did for InnoPeak and OPPO’s Health Lab between
26

27 2
Apple made its first production of documents at 6:04pm today, October 23. OPPO has not had ample
28 opportunity or time to review Apple’s production before the filing of this report.

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1 June 30-August 22. None of these documents show that Dr. Shi disclosed any trade secret information to
2 OPPO. Apple’s assertion that it obtained OPPO’s documents only after it “file[d] a motion to compel with
3
Jude DeMarchi” is patently false. OPPO’s production, and forthcoming production, were made by its own
4
volition and in good faith. Apple and OPPO agreed by joint stipulation that OPPO’s deadline to
5
substantially complete its production of documents is October 24. (Dkts. 83, 90.) OPPO produced
6

7 documents on October 9, told Apple that it would supplement that production and will do so by the

8 deadline to which the Parties' agreed, all without intervention by the Court.

9 On October 21, the Parties appeared before Magistrate Judge DeMarchi to discuss Apple’s demand
10
that OPPO expand the search for documents that it performed. Apple contended that OPPO’s search terms
11
were overly specific and designed to miss the most relevant documents. OPPO worked with Ankura to
12
create a list of search terms based on the list of file names Apple alleges Dr. Shi retained and augmented
13
that list when Apple served its Trade Secret Disclosure on September 11. OPPO has asked Apple since
14

15 the first days after this lawsuit was filed to share the documents Apple claims Dr. Shi took so that OPPO

16 would be better able to search for them. Apple refused, and even after being served with a formal request
17 for production, still has not shared them with Defendants.
18
Instead of just providing the documents, Apple created a list of hundreds of additional search terms
19
that have no indicia that they are Apple trade secret information and demanded that Defendants search for
20
generic words like “temperature” and “thermal” without qualification which are commonly used terms in
21

22 the health sensing device industry. These search terms generated hundreds of thousands of hits in the

23 instant message and email accounts for just the four individuals mentioned in Apple’s Complaint. OPPO

24 contends that the burden of reviewing every document containing any of Apple’s search terms in the
25 documents of 27 custodians outweighs the possibility that any additional responsive documents will be
26
detected. This is expedited discovery in aid of a motion for preliminary injunction and the scope should
27
be narrowly tailored.
28

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1 Judge DeMarchi directed the Parties to further meet and confer and Apple and OPPO exchanged
2 proposals on October 22 and will report to Judge DeMarchi on October 23 about any remaining disputes.
3
OPPO has already begun the process to review additional documents in an effort to resolve its dispute and
4
will produce responsive documents once the review is complete, any responsive documents have been
5
approved for export by Chinese counsel and they are processed for production.
6

7 OPPO also agreed to produce corporate designees to testify in response to Apple’s notice of

8 OPPO’s deposition pursuant to Fed. R. Civ. P. 30(b)(6) and to make the witnesses available on October

9 29 and 30. Additionally, Dr. Zeng has agreed to sit for a deposition on October 31.
10
B. Apple Has Evaded Defendants’ Discovery Requests
11
On September 18, OPPO served a limited set of interrogatories, requests for admission and request
12
for production on Apple, and Apple’s responses were due October 20. Within hours of the deadline for
13
filing this Joint Statement, Apple produced just 54 documents (with no metadata other than file names),
14

15 despite claiming that Dr. Shi stole hundreds of documents and OPPO’s discovery requests sought copies

16 of those alleged stolen documents. Certain of its interrogatory responses are evasive and the parameters
17 of its search for documents are clearly insufficient, as Apple only agreed to search Dr. Shi’s documents
18
for responsive material. OPPO has commenced the Joint Letter process to present these disputes to Judge
19
DeMarchi. Apple also served an updated Trade Secret Disclosure on October 20 demonstrating that its
20
claims are a moving target, as Apple will try to find a trade secret in the material OPPO produces rather
21

22 than identifying it in advance.

23 C. No Further Preliminary Relief is Justified

24 To resolve the need for the Court to rule on Apple’s TRO Application, Defendants stipulated to
25 “Interim Measures” that preserved the status quo and agreed that expedited discovery could begin.
26
OPPO agreed to search for the documents identified by Apple, and any materials derived from,
27
concerning or referencing those documents, on relevant OPPO IT systems to which Dr. Shi had access,
28

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1 and the OPPO and personal devices of Dr. Zeng (Dr. Shi’s devices were seized). OPPO further agreed to
2 quarantine and preserve any documents containing Apple trade secrets that it found, along with Dr. Zeng’s
3
devices and to prevent Drs. Zeng and Shi from accessing OPPO facilities and IT systems.
4
Now the search is complete, and there is no indication that OPPO received any Apple trade secret
5
information from Dr. Shi. There is consequently no basis for Apple to request preliminary injunctive relief,
6

7 and it is not entitled to any such relief. OPPO has already looked for Apple’s “trade secrets” and

8 “confidential information” and found nothing that it might disclose, retain, use or be obligated to return.

9 D. Apple’s Eleventh Hour Disclosure of Additional Relief It Will Seek May Impact the
Timing of the Motion
10

11 OPPO has asked Apple what additional relief it intends to seek, and Apple provided its first

12 outlines of what relief it may seek at 7:00am today. This belated disclosure was thin on specifics, making

13 it difficult to determine what work remains to be done and a realistic schedule for accomplishing it.
14
It is difficult to know whether Apple’s contemplated motion will require an evidentiary hearing
15
with live testimony or should be argued on the papers. It is also unclear whether Apple will produce
16
adequate documents and full discovery responses sufficiently in advance of the current due date for
17
OPPO’s opposition to the motion for preliminary injunction such that the schedule will not need to be
18

19 modified. OPPO and Apple previously stipulated to a short extension of the due dates for OPPO’s

20 document production and completion of the depositions of OPPO witnesses without impacting the
21 briefing schedule for Apple’s motion. 3 Now, however, Apple has belatedly produced a small set of
22

23 3
Apple falsely claims that OPPO “has generally objected to proceeding with the Court’s schedule but
24 has not explained why.” Yet, OPPO has complied with most every deadline in the Court’s schedule.
OPPO sought a short extension only to the due dates for OPPO’s document production and the
25 completion of deposition in light of (ongoing) negotiations with Apple regarding search terms, which
has expanded the universe of documents OPPO must review and thus pushed the timeline for
26 production, and Apple’s continued refusal to provide copies of relevant documents, failure to adequately
disclose its alleged trade secrets, rejection of OPPO’s request for contractor reviewer access to AEO
27 material, and failure to identify subject matter of alleged 1:1 conversations, among other things. As
OPPO has communicated to Apple, it is unclear how the Interim Measures fail to address Apple’s
28 concerns while these proceedings continue.

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1 documents and has given no indication as to whether it intends to produced anything additional, much
2 less when it will be substantially complete. It would be inequitable to allow Apple to require Defendants
3
to complete expedited discovery and then withhold its own responsive materials until it is too late for
4
Defendants to rely on them to oppose Apple’s request for provisional relief. OPPO encourages the Court
5
to inquire of Apple what form of injunctive relief Apple plans to seek and when Apple will produce
6

7 documents to Defendants so that a fair and reasonable briefing schedule can be set.

8
IV. INNOPEAK’S STATEMENT
9
After nearly two months of extensive investigation, searching tens of thousands of documents
10
using about 800 search terms in both English and Mandarin, offering 30(b)(6) witnesses on the full scope
11
of requested topics, and at every turn acceding to Apple’s constantly expanding discovery demands,
12
InnoPeak located two documents that match the file names of documents that Apple alleged were
13
misappropriated. But even Apple concedes that these two documents are not Apple confidential or trade
14
secret information. Expedited discovery as to InnoPeak is complete, but Apple still has not identified any
15
alleged trade secrets misappropriated by InnoPeak. Put simply—there is no evidence on which Apple can
16
credibly base its request for injunctive relief as to InnoPeak, and certainly not enough for the overbroad
17
and vague mandatory relief that Apple apparently intends to seek. Tellingly, when asked based on the
18
record evidence what that relief would look like, Apple said it was “still considering.” Only when pressed
19
again did Apple change its tune and state that it did “not believe there is any basis for different injunctive
20
measures between InnoPeak and OPPO.”
21
The evidence shows no injunctive relief against InnoPeak is appropriate. InnoPeak has fully
22
complied with its obligations as set forth in the Stipulation Regarding Interim Measures (ECF No. 30) and
23
the deadlines in the Court’s August 29, 2025 Order (ECF No. 41). Expedited discovery and InnoPeak’s
24
investigation confirmed that InnoPeak has not misappropriated any Apple trade secret or confidential
25
information. InnoPeak confirms that it will continue to comply with its obligations under the Interim
26
Measures Stipulation, which secures the status quo and adequately protects Apple’s interests moving
27
forward. Thus, preliminary injunctive relief against InnoPeak is unwarranted.
28

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1 On August 21, 2025, Apple filed a complaint for (1) breach of contract against Defendant Dr. Chen
2 Shi (“Dr. Shi”) and (2) violation of the Federal Defend Trade Secrets Act against Defendant Guangdong
3 Oppo Mobile Telecommunications Corp., Ltd. and Defendant InnoPeak Technology, Inc. (“InnoPeak”).
4 The following day, Apple moved for a Temporary Restraining Order (ECF No. 11) against the Defendants.
5 On August 25, 2025, the parties appeared before the Court and agreed to confer regarding an interim
6 measures stipulation negating the need for Apple’s TRO. The parties submitted such a stipulation the next
7 day (ECF No. 28), which the Court entered (ECF No. 30).
8 On August 28, 2025, the parties submitted a joint status report. ECF No. 38. The status report
9 included the parties’ proposals regarding (1) a briefing schedule for Apple’s preliminary injunction motion,
10 see id. at 1-7, and (2) expedited discovery, see id. at 8-13. The parties appeared again at an August 29
11 status conference to discuss the joint status report, after which the Court issued an Order with preliminary
12 injunction briefing and expedited discovery schedules. ECF No. 41.
13 Pursuant to the Interim Measures Stipulation and the Court’s August 29 Order, InnoPeak retained
14 Kroll Associates to assist in its forensic investigation relating to Apple’s trade secret misappropriation
15 allegations. Given the vague and incomplete descriptions of the alleged trade secrets in the complaint,
16 InnoPeak initially searched for the file names identified in Exhibit A attached to the Interim Measures
17 Stipulation. See ECF No. 28-1. However, several of those file names were redacted and therefore
18 InnoPeak was unable to search for them. After repeated requests from InnoPeak, Apple eventually allowed
19 Kroll to access the complete list of all 500+ unredacted file names, which are the file names disclosed in
20 Exhibits E, F, and G to the Roffman declaration filed in support of Apple’s TRO motion4. See ECF No.
21 12-5 at Exhibits E, F, and G. At that point, Kroll expanded InnoPeak’s search to include searching for all
22 file names across InnoPeak’s systems. At Apple’s request, Kroll’s file name searches included searches
23 for partial file names provided by Apple. Kroll’s searching also included searching for any hash values
24 Apple had provided associated with Apple documents and running image searches for any pictures Apple
25 provided from documents identified in its September 11 “Trade Secret Disclosure” document.
26
4
27 Exhibits E, F, and G to the Roffman declaration correspond to Exhibit A to the Interim Measures
Stipulation. Exhibits E, F, and G to the Roffman declaration are the unredacted versions of the
28 information in Exhibit A to the Interim Measures Stipulation which was redacted.

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1 In addition to searching for file names, hash values, and any specific pictures Apple had identified
2 as containing its alleged trade secrets, as part of its investigation, InnoPeak (together with Oppo) also
3 generated over 250 search terms prepared from reviewing the Trade Secret Disclosure document. Kroll
4 also ran these approximate 250 search terms over the relevant InnoPeak systems. Although InnoPeak’s
5 search terms were comprehensive, InnoPeak also solicited search terms from Apple. Apple responded on
6 September 21, 2025, with approximately 300 new search terms, many of which were overly broad (e.g.,
7 “temperature”, “thermal”, “Apple”, “Mac”, “iPad”, and “iPhone”). Two weeks later Apple provided
8 Chinese translations for those 300 terms, and the week after that Apple sent an additional 36 terms.
9 Despite their overbreadth, InnoPeak ran all 500+ terms across the custodians and ESI that Apple requested
10 and produced responsive, non-privileged documents.
11 Moreover, consistent with the Court’s August 29 Order (ECF No. 41), on September 25 InnoPeak
12 responded to Apple’s First Set of Interrogatories and First Set of Document Requests. See ECF No. 38-1
13 at 2-7, 23-27. On October 9, 2025, InnoPeak timely completed its production of documents responsive to
14 Apple’s document requests. On October 22, 2025, InnoPeak made available two Rule 30(b)(6) witnesses
15 in response to all of Apple’s noticed topics. See id. at 49-56.
16 As a result of its investigation, InnoPeak has identified only two documents that match file names
17 identified in Exhibits E, F, and G to the Roffman declaration. These documents consist of publicly
18 available information about Dr. Shi’s work experience (file name: Self Introduction.key) and thesis work
19 from Columbia (file name: Hot Pockets Forum 120922 – Tiny Injectable Sensing Device.key).
20 Nevertheless, consistent with the Interim Measures Stipulation, InnoPeak quarantined these documents.
21 InnoPeak produced the documents on October 9, 2025, and the following day informed Apple that
22 InnoPeak does not believe the two documents contain any Apple confidential information. Apple
23 confirmed on October 21, 2025, that neither document contains Apple Confidential or Highly Confidential
24 information. This means that InnoPeak did not find any of the files containing Apple Confidential or
25 Highly Confidential information in its systems.
26 In addition to satisfying Apple’s overbroad discovery requests, InnoPeak has served on Apple
27 limited discovery—three interrogatories, two document requests, and two requests for admission. Of
28 particular relevance is InnoPeak’s first document request, which seeks production of the 500+ files that

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1 Apple alleged contained trade secrets taken by Dr. Shi (i.e., those identified in Exhibits E, F, and G to the
2 Roffman Declaration (ECF No. 12-5)). While Apple was to produce documents by October 20, Apple
3 made its first document production the evening of October 23 and InnoPeak has not yet been able to
4 review its contents.
5 Apple’s disappointment that it did not find a “smoking gun” in InnoPeak’s systems is evident from
6 its portion of this Joint Report. For one, Apple consistently refers to the “OPPO Defendants” when
7 lumping together allegations of wrongdoing to make its case, but at times simultaneously acknowledges
8 that InnoPeak and OPPO are separate entities acting independently of one another. InnoPeak is not so
9 much “distanc[ing] itself from OPPO” as it is pointing out the glaring holes in Apple’s case with respect
10 to InnoPeak. Moreover, Apple makes much ado about “file listings and web browser history for Dr. Shi’s
11 InnoPeak work laptops” that it claims InnoPeak delayed production of until this week. Not only are these
12 file listings and web browser history not responsive to any of Apple’s RFPs, see ECF No. 38-1 at 2-7, but
13 Apple did not ask for this information until six days ago, and InnoPeak worked quickly to produce it
14 because it has nothing to hide. To be clear, InnoPeak’s production has been complete since October 9,
15 and if Apple thought otherwise it should have raised the issue more than three hours before this Joint
16 Report was due.
17 At bottom, InnoPeak has done all that has been asked of it, and more. Specifically, InnoPeak
18 provided substantive interrogatory responses on September 25, and searched its systems using
19 approximately 800 search terms (generated both by InnoPeak and Apple in English and Mandarin) no
20 matter how broad, to produce responsive, non-privileged documents. InnoPeak also produced witnesses
21 for deposition on all requested topics. At every stage, InnoPeak has met or exceeded the expedited
22 discovery requirements and abided by Apple’s ever-expanding requests outside of the originally-
23 prescribed discovery scope. In doing so, InnoPeak has not identified a single alleged Apple trade secret
24 in its possession.
25 InnoPeak reaffirms that it is committed to complying with its obligations under the Interim
26 Measures Stipulation until the Court orders otherwise. Specifically, InnoPeak reaffirms that if it locates
27 on its systems any (1) of the files or copies thereof identified in Exhibits E, F, and G to the Roffman
28 Declaration, (2) Apple files transferred or copied by Dr. Shi to InnoPeak, or (3) files or materials derived

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1 from, relating to, or referencing those Apple files, it will quarantine those files, designate them “Highly
2 Confidential – Attorneys’ Eyes Only,” and produce them to Apple’s counsel. See ECF No. 30 at ¶ 1.
3 Further, InnoPeak will (1) not disclose or use any of these aforementioned files except as required by law,
4 id. at ¶ 2; (2) continue to comply with its obligations under the law to preserve all documents, data, devices,
5 communications, and other evidence potentially relevant to the facts and circumstances of this case, id. at
6 ¶ 3; and (3) continue to quarantine and preserve Dr. Zeng’s and Dr. Shi’s company-issued devices in
7 InnoPeak’s possession and prevent Drs. Zeng and Shi from accessing InnoPeak’s systems and facilities,
8 id. at ¶ 4.
9 Given that there is no evidence of any alleged Apple trade secrets in InnoPeak’s possession and
10 InnoPeak’s commitment to abide by the Interim Measures Stipulation to maintain the status quo as the
11 case proceeds, there simply is no basis for Apple to move for a preliminary injunction against InnoPeak.
12 The Court should vacate the preliminary injunction briefing schedule as it applies to InnoPeak. But, if
13 preliminary injunctive briefing moves proceeds, InnoPeak agrees to the proceedings taking place on the
14 currently ordered schedule as set forth in ECF No. 41.
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1 Dated: October 24, 2025 Respectfully Submitted,

2 /s/ Leslie M. Schmidt /s/ Annabel Hayoung Chang
Adam R. Alper (SBN: 196834) Annabel Hayoung Chang (SBN: 267261)
3 adam.alper@kirkland.com annabel@ahc-law.com
Laura Vartain Horn (SBN: 258485) 39116 Fremont Hub #1121
4 laura.vartain@kirkland.com Fremont, CA 94536
KIRKLAND & ELLIS LLP Telephone: (510) 404-8186
5 555 California Street
San Francisco, CA 94104 Attorney for Defendant Chen Shi
6 Telephone: (415) 439-1400
/s/ Robyn Carrico Crowther
7 Michael W. De Vries (SBN: 211001) Robyn Carrico Crowther (SBN: 193840)
michael.devries@kirkland.com Rcrowther@steptoe.com
8 KIRKLAND & ELLIS LLP Sara Alwash Morse (SBN: 347086)
695 Town Center Drive smorse@steptoe.com
9 Costa Mesa, CA 92626 STEPTOE LLP
Telephone: (714) 982-9922 633 West Fifth Street, Suite 1900
10 Los Angeles, CA 90017
Leslie M. Schmidt (admitted pro hac vice) Telephone: (213) 439-9428
11 leslie.schmidt@kirkland.com
KIRKLAND & ELLIS LLP Attorneys for Defendant Guangdong Oppo
12 601 Lexington Avenue Mobile Telecommunications Corp., Ltd.,
New York, NY 10022-4611
13 Telephone: (212) 446-4800 /s/ Randall Evan Kay
Randall Evan Kay (SBN: 149369)
14 Maria M. Beltran (SBN: 327237) rekay@jonesday.com
maria.beltran@kirkland.com JONES DAY
15 KIRKLAND & ELLIS LLP 4655 Executive Drive, Suite 1500
2049 Century Park East, Suite 3700 San Diego, CA 92121
16 Los Angeles, CA 90067 Telephone: (858) 314-1139
Telephone: (310) 552-4200
17 Jennifer Diane Bennett (SBN: 235196)
Attorneys for Plaintiff Apple Inc. jenniferbennett@jonesday.com
18 Matthew Chung (SBN: 339854)
mchung@jonesday.com
19 JONES DAY
555 California Street, 26th Floor
20 San Francisco, CA 94104-1500
Telephone: (415) 875-5795
21
Attorneys for Defendant InnoPeak
22 Technology, Inc.
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1 ATTESTATION: Pursuant to Local Rules 5-1(i)(3) I hereby attest that concurrence in the filing of this
2 document has been obtained from Annabel Hayoung Chung, Robyn Carrico Crowther and Randall Evan
3
Kay.
4

5
/s/ Leslie M. Schmidt
6 Leslie M. Schmidt
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JOINT STATUS REPORT 22 CASE NO. 5:25-CV-07105-EKL