In a Feb. 29 complaint, Meta alleges that Dipinder Singh Khurana of Danville, California, who is also known as T.S. Khurana, uploaded Meta's highly confidential internal data onto his personal cloud accounts, including information on Meta's vendor contracts, employee performance reviews, compensation data and a list of Meta's "top talent" employees, before leaving the company to join an early-stage cloud computing services startup operating in "stealth mode" as its senior vice president of supply chain.
Meta alleges that Khurana has repeatedly accessed and used the confidential information at his new job, and has shared it with his colleagues in an effort to recruit Meta's top talent and in "utter disregard" for his contractual obligations and employment agreements with Meta.
"Meta is also informed and believes that Khurana continues to be in a position where Meta's information may be useful, and/or financially beneficial, to him," the suit says.
The suit argues that without a court order, Khurana will continue to have access to confidential information on Meta's data centers and its supply chain that "would give Khurana and his new company a valuable advantage that, on its own, would take Khurana and his new company years to learn on their own."
Khurana was a vice president of infrastructure at Meta for more than a decade, from May 2011 through early June 2023, where he managed engineering teams totaling more than 300 workers and had access to Meta's proprietary data, according to the suit.
That confidential data included detailed information regarding Meta's supply-chain organizational plans, supplier and vendor contracts with Meta's pricing and supply information, Meta's AI roadmaps and performance and compensation data about Meta's employees, the complaint says.
Khurana notified Meta on May 15 that he planned to leave as of June 1, but Meta alleges that during the weeks before his departure, he uploaded hundreds of confidential Meta files and documents, including Meta's supply contracts and employee data, from Meta's systems onto his personal Google Drive and a Dropbox account bearing the name of his new employer.
Meta alleges that Khurana was so brazen in his disregard for his obligations to Meta that on the day he informed the company he planned to resign, he emailed his subordinates asking workers to send him confidential vendor contracts with crucial components for Meta's data centers, which he then moved to his personal accounts to use at his new job.
Upon his resignation on May 22, Khurana also refused to sign Meta's termination certificate, which specifically referenced his obligations to keep Meta's information confidential, according to the complaint.
Since Khurana's departure, between June and November, at least eight Meta employees listed in Meta's top talent spreadsheet have left to join Khurana's new employer, according to the suit, which says at least some of the departures resulted from Khurana's alleged misappropriation of Meta's confidential data.
Meta also claims that multiple other Meta employees identified in the spreadsheet have been contacted by Khurana's new employer, which "likely also resulted from Khurana's use and/or disclosure of non-public information regarding Meta employees."
Meta notified Khurana's new employer in November of its concerns about its confidential data, but Khurana has repeatedly denied sharing Meta files with his new employer or initiating contact with Meta workers seeking to get hired at his new employer, according to the complaint.
"Despite this, Meta is informed and believes that Khurana contacted, in the first instance, multiple Meta employees — including, significantly, employees who were listed in the 'Top Talent' spreadsheet of Meta employee information taken by Khurana when leaving Meta," the complaint says.
The complaint asserts claims of breach of contract, breach of duty of loyalty, breach of fiduciary duty, unjust enrichment and violations of the California Computer Data Access and Fraud Act.
The suit seeks an injunction against Khurana and any co-conspirators, as well as restitution and compensatory, special, consequential and punitive damages, plus interest, attorney fees and costs. The complaint additionally asks the court to order Khurana to disgorge all compensation, stock, benefits and any other profits he unlawfully obtained.
A case management conference is scheduled for July 15, before Contra Costa Superior Court Judge Danielle K. Douglas.
Meta said in a statement Tuesday that the company takes "this kind of egregious misconduct seriously" and "We will continue working to protect confidential business and employee information."
Khurana didn't immediately respond to a request for comment Tuesday.
Khurana has an undergraduate degree in electrical engineering from the University of Rochester and an MBA from Santa Clara University, according to his LinkedIn profile.
After receiving his graduate degree, he worked as a marketing manager and later executive at KLA-Tencor Corp. a semiconductor, LED inspection and metrology technology company, for a few years in the 1990s before getting hired at Cisco Systems in 1999, his LinkedIn profile says.
Khurana held a variety of positions at Cisco, and when he left nearly 12 years later to join Meta, he was senior director of operations, his profile says.
Meta is represented by Rachael E. Meny, Paven Malhotra and Victor H. Yu of Keker Van Nest & Peters LLP.
Counsel information for Khurana wasn't immediately available Tuesday.
The case is Meta Platforms Inc. v. Dipinder Singh Khurana, case number C24-00545, in the Superior Court of the State of California, County of Contra Costa.
--Editing by Alanna Weissman.
For a reprint of this article, please contact reprints@law360.com.
