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CreateAI Holdings Inc v Bot Auto TX Inc

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Case Information
Case name CreateAI Holdings, Inc. f/k/a TuSimple Holdings, Inc. v. Bot Auto TX Inc.[1]
Court Texas Fifteenth Court of Appeals; appeal from Texas Business Court, Division 11A[1]
Docket 15-25-00001-CV; trial cause 24-BC11A-0007[1]
Filed Appeal opened January 2, 2025; original petition’s exact filing date not identified in the sources reviewed[2]
Judge(s) Appellate panel: Chief Justice Scott A. Brister and Justices Field and Farris; trial judge Sofia Adrogue[1][2]
Plaintiffs CreateAI Holdings, Inc., formerly TuSimple Holdings, Inc. (appellant)[1]
Defendants Bot Auto TX Inc. (appellee)[1]
Case type Autonomous-vehicle technology trade-secret dispute; interlocutory injunction appeal[1]
Claims / issues Texas Uniform Trade Secrets Act; alleged use of sensor, data-annotation and safety technology; probable recovery and irreparable injury[1]
Status September 15, 2026: appellate court affirmed denial of a temporary injunction on the preliminary record[3][1]

CreateAI Holdings, Inc. v. Bot Auto TX Inc. is a Texas trade-secret dispute concerning autonomous-trucking technology. CreateAI, formerly TuSimple, alleges that competitor Bot Auto used its proprietary sensor, decision-making and safety technology. On September 15, 2026, the Texas Fifteenth Court of Appeals affirmed denial of CreateAI’s requested temporary injunction. The opinion expressly limits its decision to the preliminary record and the requirements for temporary relief; it does not finally adjudicate liability for misappropriation.[1][3]

Background and requested relief

The appellate opinion describes CreateAI’s development of driverless trucking and its later move toward AI-powered entertainment. It identifies Bot Auto as an autonomous-trucking company founded by former TuSimple chief executive Xiaodi Hou after his departure. This background is the court’s account of the injunction record.[1]

CreateAI sued under the Texas Uniform Trade Secrets Act, seeking damages and temporary and permanent injunctive relief. The parties initially agreed to a restraining order restricting transfer or dissemination of disputed technology, with an exception for ordinary work with suppliers and contractors under customary nondisclosure agreements. After discovery and a November 18–19, 2024 evidentiary hearing, the trial court denied a temporary injunction and dissolved the restraining order. The appellate judgment identifies the challenged trial ruling as signed December 28, 2024.[1][3]

Appellate analysis

The court reviewed the temporary-injunction ruling for abuse of discretion. It considered whether CreateAI showed a probable right to recovery and a probable, imminent and irreparable injury, rather than deciding the entire dispute after a merits trial.[1]

Sensors and data annotation

For the sensor array, the court emphasized CreateAI’s public disclosure of sensor locations and types in an investor presentation. It also cited differences in the companies’ sensors, placement, data formats and processing technology as evidence supporting the trial court’s refusal to grant preliminary relief.[1]

CreateAI also alleged copying of its conventions for labeling road-trip data used to train autonomous-driving systems. The court found that the shared use of red and green categories did not establish the broader copying alleged. It relied on evidence of differences between CreateAI’s convolutional-neural-network systems and Bot Auto’s transformer-based system, including their annotation requirements and the possible usefulness of CreateAI’s conventions to Bot Auto.[1]

This discussion concerns the technologies and testimony in this record. The opinion notes that the record did not explicitly establish that Bot Auto used self-supervised training. Its reasoning does not supply a general rule that transformer systems cannot use another company’s training information.[1]

Safety technology and irreparable injury

The court treated redundancy as a general safety principle and found that use of dual braking-control buses did not itself establish misappropriation. It cited CreateAI’s earlier public disclosure and evidence of different components and protocols. For steering technology, it pointed to differing technical requirements and distinguished a product’s performance specifications from the means used to achieve them.[1]

The court also found support for denying relief on irreparable-injury grounds. It questioned the claimed imminent harm given CreateAI’s retreat from U.S. autonomous trucking and explained that lost licensing royalties could be measured and compensated with damages. This was an assessment of the preliminary injunction record, not an award of damages.[1]

Disposition and procedural status

The September 15 memorandum opinion and judgment affirmed the trial court’s ruling and assessed appellate costs against CreateAI. The public appellate register reviewed October 18 lists that opinion and judgment and a future November 25 mandate-calendar entry. A calendar entry does not establish that a mandate has already issued. These records do not establish the later disposition of the underlying damages or permanent-injunction claims.[1][3][2]

References

  1. ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 1.11 1.12 1.13 1.14 1.15 1.16 1.17 1.18 Texas Fifteenth Court of Appeals, CreateAI Holdings, Inc. f/k/a TuSimple Holdings, Inc. v. Bot Auto TX Inc., No. 15-25-00001-CV, memorandum opinion, September 15, 2026, pp. 1–13.
  2. ↑ 2.0 2.1 2.2 Texas Judicial Branch, No. 15-25-00001-CV, public appellate docket, reviewed October 18, 2026.
  3. ↑ 3.0 3.1 3.2 3.3 Texas Fifteenth Court of Appeals, No. 15-25-00001-CV, judgment rendered September 15, 2026, 1 page.
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