Summary of pleading
] - 31234567891011121314151617181920212223242526272829303132built in America in order to deliver extensive American jobs nationwide. Noother applicant,
or award “winner”
, has succeeded in meeting, or intending tomeet, that milestone.XP Technology developed a patented lightweight, low-cost,long-range, electric vehicle using air-expanded foam-skinned material for aportion of the polymer body and received numerous patents, acclaim and superiorcomputer modeling metrics over any competing solution. XP presented a vast setof letters of support to DOE from pending customers. Major auto-industryfacilities and engineers had joined forces to bring the vehicle to the defense,commercial and consumer market.3.
Plaintiff reserves the right to join this case with the cases of otherapplicants should those parties elect to further participate.4.
Defendant, the United States of America, for all purposes relevant hereto,
acted by and through the Department of Energy (“DOE”), an agency of the federal
The DOE ATVM and Loan Guarantee were offered to XP by elected officials. Asoriginally worded, the program was applicable only to four-wheeled passengervehicles. In October 2009, a bill sponsored by California Representatives BrianBilbray and Adam Schiff, on behalf of Aptera, was passed extending the
program’s coverage to include high mileage (75 mpg equivalent) two
- and three-wheeled vehiclesThe U.S. Department of Energy (DOE) announced in December 2008 the selection ofsix cost-shared research projects for the development and demonstration ofalternative vehicle technology projects totaling a DOE investment of up to$14.55 million over three years, subject to annual appropriations. Privatesector contributions will further increase the financial investment for a total