Takata Corporation

CourtUnited States Bankruptcy Court, D. Delaware
DecidedJune 18, 2020
Docket18-50274
StatusUnknown

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Bluebook
Takata Corporation, (Del. 2020).

Opinion

UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: Chapter 11

TK HOLDINGS INC., et al., Case No. 17-11375 Debtors. Jointly Administered Adv. Pro. No. 18-50274 Automotive Coalition for Traffic Safety, Inc.

Plaintiff,

v.

Joseph J. Farnan, Jr., not individually but solely as Trustee of the Reorganized TK Holdings Trust, and Joyson Safety Systems Acquisition, LLC,

Defendants.

MAYER BROWN LLP BENESCH, FRIEDLANDER, COPLAN James R. Ferguson, Esq. & ARONOFF LLP Melissa A. Anyetei, Esq. Stephen M. Ferguson, Esq. 71 S. Wacker Drive 222 Delaware Avenue, Suite 801 Chicago, Illinois 60606 Wilmington, Delaware 19801

KLEHR HARRISON HARVEY BROOKS KUSHMAN P.C. BRANZBURG LLP Frank A. Angileri, Esq. Richard M. Beck, Esq. Linda D. Mettes, Esq. Sally E. Veghte, Esq. Robert C.J. Tuttle, Esq. 919 N. Market Street, Suite 1000 Amy C. Leshan, Esq. Wilmington, Delaware 19801 1000 Town Center, 22nd Floor Southfield, Michigan 48075 Morton R. Branzburg, Esq. 1835 Market Street, Suite 1400 Attorneys for Defendant Joyson Safety Philadelphia, Pennsylvania 19103 Systems Acquisition LLC

Attorneys for Plaintiff Automotive Coalition for Traffic Safety, Inc. OPINION1

Before the Court are cross-motions for summary judgment in this Adversary Proceeding. The dispute centers on ownership of certain patents rights (the “Patent Assets”)2. Automotive Coalition for Traffic Safety (“ACTS” or the “Plaintiff”) brought an adversary proceeding against Chapter 11 debtor, TK Holdings Inc. (hereinafter, “Takata”) seeking a declaratory judgment that certain Patent Assets are not the property of the bankruptcy estate because they belong to ACTS. Takata contends that the Patent Assets belong to it and may thus be sold and transferred to Joyson Safety Systems Acquisition LLC (“Joyson”) under the terms of Takata’s Fifth Confirmed Amended Joint Chapter 11 Plan of Reorganization (the “Plan”).3 For the reasons that follow, the Court finds that under the terms of the contract executed by the parties, the Patent Assets are the property of ACTS, not Takata, and therefore were not transferred to Joyson under Takata’s Plan. Summary Judgment will be entered in favor of ACTS, and Takata’s cross-motion will be denied.

1 This Opinion constitutes the findings of fact and conclusions of law of the Court pursuant to Federal Rule of Bankruptcy Procedure 7052. To the extent that this Court's authority is determined to be within the parameters of 28 U.S.C. § 157(c)(1), this Opinion and the accompanying Order shall be deemed to be the Court's proposed findings of fact and conclusions of law pursuant to Federal Rule of Bankruptcy Procedure 9033. 2 ACTS’ Complaint defines the “Patent Assets” as: (a) U.S. Provisional Patent Application No. 61/451,082, filed on March 9, 2011 (“the ‘082 Application”); (b) U.S. Patent Application No. 13/415,767, filed March 8, 2012, which matured into U.S. Patent No. 8,479,864; (c) U.S. Patent No. 8,479, 864, which issued July 9, 2013 (“the ‘864 Patent”); (d) International (PCT) Patent Application No. PCT/US2012/028295, filed March 8, 2012 (“PCT ‘295”); (e) European Patent Application No. 12754647.1, filed March 8, 2012 (“EP ‘647”); (f) Japanese Patent No. JP6121916 (B2), filed March 8, 2012 and issued April 7, 2017; (g) Chinese Patent Nos. CN103476623, filed March 8, 2012 and issued November 9. 2-16 and (h) any and all other U.S. or foreign patents or patent applications which claim benefit of the foregoing patents and/or patent applications. 3 Findings of Fact, Conclusions of Law, and Order Confirming the Fifth Am. Joint Chapter 11 Plan of Reorganization of TK Holdings Inc. and its Affiliated Debtors, Feb. 21, 2018, Docket No. 2120 (“Order Confirming Plan”). I. BACKGROUND A. General

Prior to commencing these Chapter 11 proceedings, Takata was a leading global developer and manufacturer of automotive safety and non-safety systems, including airbags and seat-belts.4 The record reflects that, among other products, Takata manufactured airbag inflators containing phase-stabilized ammonium nitrate (“PSAN”), which had the potential to rupture upon airbag deployment, causing death and serious injury to automobile occupants. In response to multiple reports of injuries caused by PSAN inflators in vehicles, the National Highway Traffic Safety Administration (“NHTSA”) initiated the largest product recall in U.S. history. Takata filed for Chapter 11 protection on June 25, 2017. Takata’s Plan was structured around a sale of substantially all of its assets to Joyson. Included in that proposed sale were the Patent Assets at issue here. ACTS timely filed a Limited Objection to confirmation of Takata’s proposed plan (the “Objection”).5 As described more fully below, ACTS objected to the proposed sale of U.S. Provisional Patent Application No. 61/451,022 (the “082 Application”) and certain

other patents and patent applications, contending that these Patent Assets were the property of ACTS, not Takata, and thus could not be sold to Joyson under the Plan. To resolve ACTS’ Objection in advance of the confirmation hearing, the parties agreed that the Plan could be confirmed and the question of ownership of the Patent Assets would be reserved for later disposition. In a nutshell, the parties carved the Patent Assets out of the sale to Joyson; if Joyson prevails here, it will be the owner of the Patent Assets. If ACTS prevails, then it is the owner and the Patent Assets will not have been sold and transferred under the Plan.

4 As the instant dispute between these parties has little to do with the circumstances leading to Takata’s collapse, the Court provides here only the most general overview of these otherwise enormously complex Chapter 11 proceedings. 5 Limited Objection to Confirmation of the Third Am. Joint Chapter 11 Plan of Reorganization of TK Holdings Inc. and its Affiliated Debtors, Feb. 6, 2018, Docket No. 1948. The Court entered an order confirming Takata’s Plan on February 21, 2018.6 As noted, the Order confirming the Plan specifically preserved ACTS’ Objection until a later hearing date and did not include the Patent Assets in the sale.7 ACTS filed a Complaint and commenced this Adversary Proceeding against Takata

seeking a declaration that ACTS owns the Patent Assets and further seeking an injunction barring Takata from selling the Patent Assets in its bankruptcy case.8 Takata has responded and asserted in its Answer that the Patent Assets are property of Takata’s bankruptcy estate, are not owned by ACTS and were properly sold and transferred to Joyson under the Plan. B. The Patent Assets ACTS partnered with NHTSA in 2008 to develop a new alcohol detection system that would help prevent alcohol-impaired driving. The research program, called the Driver Alcohol Detection System for Safety (“DADSS”), was to proceed in two phases. Phase I of the project contemplated the development of a touch-based alcohol detection sensor (the “Sensor”) to measure a driver’s blood alcohol level from the driver’s fingertip. During Phase II, the Sensor would be

further developed so that it could be incorporated into a motor vehicle. ACTS hired TruTouch Technologies, Inc. (“TruTouch”) to develop the sensor for Phase I of the project, which concluded in late 2010. For Phase II, ACTS required that TruTouch partner with an automobile manufacturer to develop a product that could operate reliably in an automobile. ACTS issued a Request for Proposal9 (“RFP”), and the record reflects that TruTouch contacted Takata representatives to partner with Takata on the project and utilize Takata’s deep

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