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Nick Gicinto, who is named in a statement about the complaint, formerly ran Uber's Strategic Services Group. The group was accused of unauthorized surveillance of competitors, including recording private conversations and wiretapping, in an explosive piece of evidence revealed during the lawsuit between Uber and Alphabet's self-driving car company, Waymo, earlier this year.
The complaint, filed to the SEC by Tesla ex-security employee Karl Hansen, accuses Tesla's security team of unauthorized wiretapping and "hacking" of employee cell phones and computers, including accessing the cell phone of Martin Tripp, another Tesla whistleblower, after he was fired. Hansen says that Tesla CEO Elon Musk "specifically authorized" these tactics.
The Uber memo, dubbed the Jacobs Letter, contained a long list of unethical surveillance techniques allegedly used by Gicinto and others while trying to obtain trade secrets from competitors such as Waymo and DiDi Chuxing. At the time, Uber said it hadn't substantiated all the claims in the letter but that "going forward [it] would compete honestly and fairly."
Uber and Waymo settled the high-profile case in February, with Uber paying Waymo an equity stake worth approximately $245 million.
In April, four Uber security managers, including Gicinto, sued the author of the letter, Richard Jacobs, for defamation.
The complaint against Tesla alleges that Gicinto now leads Tesla's security unit, and that there are several other former Uber employees on the team as well, "despite the revelation of a purported investigation by the U.S. Attorney's Office in San Francisco this past December 2017 as to the actions related to the Uber security team."
It additionally alleges theft and drug dealing at one of Tesla's factories.
In a statement to CNBC, a Tesla spokesperson called some of Hansen's allegations "outright false" and said others "could not be corroborated." The company said it made "numerous attempts" to get more information from Hansen.
"He rejected each of those attempts, and to date has refused to speak with the company further," Tesla said. "It seems strange that Mr. Hansen would claim that he is concerned about something happening within the company, but then refuse to engage with the company to discuss the information that he believes he has."
The accusations against Tesla come as Musk faces scrutiny for a controversial tweet last week in which he said he was looking to take the company private at $420 a share with "funding secured." The SEC has reportedly served Tesla with a subpoena to determine whether the tweet violated SEC rules that public statements made by company executives must be true.
Here is the release about the most recent SEC complaint:
This embed has been updated to reflect that Stuart Meissner reissued a corrected statement.
Here is the original Jacobs letter with allegations about Gicinto and his team: