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Here's the Chipotle Ramen Concept Lawsuit, in Full

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As reported earlier today, ex-Fat Duck chef and ex-Chipotle employee Kyle Connaughton has filed a lawsuit against CEO Steve Ells concerning secrets, ramen shops, and David Chang. Now Eater has obtained a copy of the suit.

The thing reads beginning to end like a fast/casual corporate thriller: it alleges that Connaughton was purposefully lied to by Ells concerning some consulting David Chang and Momofuku had done on a Chipotle-style ramen chain. After Chang pulled out of the deal around 2008, Connaughton was brought on to execute a new restaurant concept which would have been/will be called Ramen Yokocho.

The suit claims Connaughton only discovered Chang's prior involvement sometime in October 2012 when an exec let it slip that "Momofuku will sue Chipotle when the ramen concept opens." (Note: It is unclear if Momofuku actually intends to sue Chipotle should they open a ramen shop. They declined to comment on this story.) Sometime after this discovery, Connaughton was fired, and now he's suing for wrongful termination, seeking damages and promised equity. Below, the timeline as it stands in the lawsuit and the actual suit itself, which is totally worth a read:


The Timeline According to the Lawsuit

Events below are allegations against Chipotle on the part of the plaintiff and have not been confirmed by other sources.

2008
Again, this is alleged by the lawsuit and not confirmed by Momofuku, but supposedly Chang entered a "confidential business dealing whereby Mr. Chang agreed to develop a ramen concept" with Ells. Ells signed an NDA which covered "Chang's ramen concept, including menus and other business development ideas." Somehow (the suit doesn't elaborate) Momofuku worked on the design for the ShopHouse flagship. At some point the "business dealing" ended; Ells asked Chang to tear up the NDA and Chang refused.

2010
Chef Kyle Connaughton, who worked for Heston Blumenthal and Michel Bras among others, comes up with an idea for a fast food ramen restaurant and begins developing it on his own.

August, 2010
Connaughton starts shopping the ramen idea around, at which point Chipotle becomes interested in the concept.

February 2011
Connaughton signs a contract with Chipotle.

2011
Connaughton continues to develop the ramen concept exclusively for Chipotle. At some point during this process, "Ells and other Chipotle staff, communicated their own ideas concerning menu items, kitchen designs, service platform, restaurant interior, and packaging specific to ramen" which Connaughton later comes to believe have originated in the Momofuku consultation.

September 2011
The first ShopHouse opens in DC.

September 2012
Chipotle signs a lease on a space for the ramen shop in Manhattan, on 12th Street and University.

October 2012
At some point, Connaughton decides to go to Noodle Bar to "taste food and meet the outgoing head chef," whom he is interested in hiring for the ramen concept. He brings two Chipotle execs: Mark Crumpaker and Tim Wildin. At some point during the dinner, Crumpaker told Connaughton that Chipotle will not hire ex-Momofuku employees and "Momofuku will sue Chipotle when the ramen concept opens but that Mr. Ells made a decision to proceed anyway." Connaughton confronted Ells and was told to continue working on the ramen project.

Connaughton claims this is the first time he heard of Chang's involvement, although Chang gave AdWeek an interview in August of 2012 in which he said, "There is a very successful fast-food company that approached us and quite frankly took our intellectual property. And they are running our concept right now. They have two stores that have opened up." This was widely believed at the time to be Chipotle.

November 17, 2012
Connaughton is fired from Chipotle for allegedly violating his contract and "because he no longer had confidence in the ramen project."

June 3, 2013
Connaughton files suit against Chipotle and Ells, seeking the value of his equity with the company and damages. The amount is unspecified.


Kyle Connaughton vs. Chipotle Mexican Grill, Inc. and Steven Ells

· All Chipotle Coverage on Eater [-E-]
· All Lawsuit Coverage on Eater [-E-]

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