This is a breach of contract action arising from years of gross negligence and failure to live up to industry standards by Tesla with respect to solar panels that Tesla designed, installed, and promised to operate and maintain safely on the roofs of hundreds of Walmart stores.

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Why were multiple Walmart stores located all over the country suddenly catching fire? The answer was obvious and startling: the stores all had Tesla solar panels installed by Tesla on their roofs. At each location, the fire had originated in the Tesla solar panels.

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By May 2018, it was clear that Tesla had breached its contractual obligations. To state the obvious, properly designed, installed, inspected, and maintained solar systems do not spontaneously combust, and the occurrence of multiple fires involving Tesla’s solar systems is but one unmistakable sign of negligence by Tesla. To this day, Tesla has not provided Walmart with the complete set of final “root cause” analyses needed to identify the precise defects in its systems that caused all of the fires described above. The number of defects, however, is overwhelming and plainly indicative of systemic, widespread failures by Tesla to meet the standard of care, as set forth in the governing contracts, as to the solar systems installed at Walmart’s stores.

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Unfortunately, even de-energization was not enough to prevent an additional fire. In November 2018, Walmart discovered that yet another fire had occurred at a Walmart store in Yuba City, California-even though the solar panels at this store had been de-energized since June 2018. Wires on the store’s rooftop were still sparking at the time that Walmart discovered the fire and could have ignited more extensive flames, with potentially devastating consequences. Equally troubling, after Tesla technicians visited the rooftop, one of the technicians failed to close the cover to a combiner box, exposing this important piece of equipment to the elements and thereby creating a fire hazard. Still more troubling, Walmart subsequently learned (independent of Tesla) that a potentially dangerous ground fault alert had occurred at the Yuba City site during the summer of 2018. Tesla either ignored the alert or deliberately failed to disclose it to Walmart. The issues that caused that ground fault alert likely caused or contributed to the subsequent fire in the fall of 2018, revealing Tesla’s utter incompetence or callousness, or both.