>One of the oldest rules taught from the playground is when property belongs to someone else, you return it. Here, Tesla owns specialized manufacturing tooling in Angstrom’s possession. Tesla designed the tooling, paid for it in full, and has an unconditional contractual right to retrieve it. Tesla demanded the return of its property. Angstrom refused. Now, this Court’s intervention is required to prevent immediate and irreparable harm to Tesla.

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>Tesla’s on-hand supply of the parts produced using the Tooling is dwindling and will be exhausted shortly due to Angstrom’s refusal to ship Tesla’s parts currently in its possession. Without access to its own Tooling, Tesla’s Cybertruck production line will be impacted, causing immediate and irreparable harm to Tesla, its reputation, its employees, its customers, and its other suppliers (and those suppliers’ employees) that no monetary award can remedy.