Truckin’

CreateAI Holdings, Inc. v. Bot Auto TX Inc. affirmed the denial of a temporary injunction in a TUTSA case involving two autonomous-trucking companies. The Fifteenth Court held, inter alia:

• As to a sensor array, the court found that “CreateAI publicized the exact locations and varieties of its sensors in an investor presentation in 2022,” so “an external sensor array on a self-driving vehicle may be no more secret than side-view mirrors of a traditional vehicle”
• As to a data-labeling “semantic regime,” “the record contains evidence that CreateAI’s semantics regime and data annotation conventions are of no use to Bot Auto” given that Bot Auto’s “transformer neural network… has no need to engage in large-scale manual data annotation and no use for data conventions developed by CreateAI.” (In other words, it was a later-generation AI model.)
• As to safety technology, “[r]edundancy itself is not a trade secret,” and that “the steering requirements of the two companies are not identical,” so “[e]ven if identical requirements were sufficient to prove the misappropriation of trade secrets, they simply describe the standard to which a product is built, not the means by which a product reaches that standard.”

The Court also questioned whether there was evidence of irreparable injury that could not be compensated with a reasonable-royalty award. No. 15-25-00001-CV /(Sept. 15, 2026).