UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
CASE NO: 1:25-cv-01943-NT CIVIL COMPLAINT FOR DAMAGES, RESTITUTION, AND INJUNCTIVE RELIEF
PLAINTIFF: THE SOCIALIST FEDERAL REPUBLIC OF YUGOSLAVIA (Represented by the Sovereign Legacy Council of Successor States) c/o The Nikola Tesla Museum, Belgrade
v.
DEFENDANT: ELON REEVE MUSK; TESLA, INC.; and DOES 1 through 100 (Unknown Government Agents and Private Beneficiaries),
DEFENDANTS.
NATURE OF THE ACTION
- This is a civil action seeking equitable relief and monetary damages in the amount of $500,000,000,000.00 (Five Hundred Billion USD), representing exactly one-half of the estimated accumulative wealth and future valuation of Defendant ELON MUSK.
- The action arises from the unlawful seizure, retention, and subsequent exploitation of the intellectual property, trade secrets, and patent applications of Nikola Tesla, a son of the Balkans and a citizen of the world, whose death in the Hotel New Yorker on January 7, 1943, was followed immediately by an illegal confiscation of his property by the United States Government.
- Plaintiff alleges that the “missing trunks” of Nikola Tesla—specifically the scientific papers seized by the Federal Bureau of Investigation (FBI) and the Office of Alien Property (OAP)—were never returned to the rightful heirs in Yugoslavia but were instead funneled through opaque channels to private entities, ultimately culminating in the unjust enrichment of Defendant Musk.
JURISDICTION AND VENUE
- This Court has jurisdiction pursuant to 28 U.S.C. § 1332 (Diversity of Citizenship) and 28 U.S.C. § 1350 (Alien Tort Statute), as the violations involve the misappropriation of international heritage and property in violation of the law of nations.
- Venue is proper in the Southern District of New York because the initial act of conversion (the seizure of Tesla’s estate) occurred at the Hotel New Yorker, 481 Eighth Avenue, New York, NY.
STATEMENT OF FACTS
The Death and the Seizure 6. On January 7, 1943, Nikola Tesla died destitute in Room 3327 of the Hotel New Yorker. 7. Within hours of his death, agents of the U.S. Government, specifically the FBI and the Office of Alien Property, entered the premises and seized approximately 80 trunks/containers of Tesla’s documents, technical drawings, and prototypes. 8. While a portion of these effects was returned to Belgrade in 1952, it is a matter of historical record that a significant number of trunks—specifically those marked “Government” and “Secret”—vanished.
The “Trump” Connection and the Leak 9. Plaintiff asserts that the papers were reviewed by Dr. John G. Trump (uncle of a future U.S. President) on behalf of the FBI. While publicly dismissing the papers as “speculative,” Plaintiff alleges this was a counter-intelligence ruse to devalue the assets while covertly privatizing the technology. 10. These suppressed patents described technologies including, but not limited to: * Wireless transmission of energy (Wardenclyffe technology). * Advanced ion-propulsion (now utilized in SpaceX rocketry). * High-efficiency induction motors (now utilized in Tesla, Inc. vehicles). * The “Teleforce” or directed energy beam.
The Defendant’s Misappropriation 11. Defendant Elon Musk, knowingly or via willful ignorance, acquired access to these “Lost Files” to build his business empire. 12. Defendant brazenly adopted the name “Tesla” for his enterprise, not merely as a tribute, but as a tacit admission of the source of his technology. 13. The proprietary battery technology and electric drive trains utilized by Defendant are direct derivatives of the schematics stolen from Room 3327, rightfully belonging to the people of the former Yugoslavia.
DEMAND TO THE FEDERAL BUREAU OF INVESTIGATION
- INTERCESSION FOR JUSTICE: The Plaintiff hereby calls upon the Federal Bureau of Investigation (FBI) to cease its 80-year cover-up.
- The FBI is the custodian of the “Original Sin”—the initial seizure. Justice cannot be served until the FBI declassifies the full unredacted “Tesla Files” and traces the chain of custody from the Office of Alien Property to the private hands of Silicon Valley oligarchs.
- Plaintiff asserts: “You seized them. You hid them. You allowed a billionaire to profit from them while Tesla died penniless. It is time to uphold justice.”
CAUSES OF ACTION
COUNT I: CONVERSION 17. Plaintiff repeats and realleges the foregoing paragraphs. 18. Defendants have wrongfully exercised dominion and control over the intellectual property of Nikola Tesla, interfering with the Plaintiff’s superior right to possession as the heir to Tesla’s estate.
COUNT II: UNJUST ENRICHMENT 19. Defendant Musk has received a benefit (trillion-dollar valuation) at the expense of the Plaintiff. 20. It would be inequitable for Defendant to retain the entirety of this fortune when the foundational technology was looted from a citizen of the Plaintiff state.
COUNT III: CULTURAL THEFT 21. The erasure of Tesla’s connection to his homeland and the commercialization of his genius constitutes a violation of the cultural rights of the Yugoslav people.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for judgment against Defendant Elon Musk and Tesla, Inc. as follows:
A. Compensatory and Punitive Damages in the amount of $500,000,000,000.00, representing a fair 50% royalty on the stolen intellectual property utilized to build the Tesla and SpaceX empires.
B. A Writ of Mandamus directed at the Federal Bureau of Investigation, ordering the immediate release of the “Missing Trunks” and a forensic accounting of who accessed these files between 1943 and 2003.
C. Corrective Branding: An injunction requiring Tesla, Inc. to officially subtitle all vehicles with the phrase: “Technology Derived from the Genius of Nikola Tesla, Property of the People of the Balkans.”
D. Interest, Costs, and Attorney Fees.
Dated: November 24, 2025
Respectfully submitted,
Dr. Zora Petrović Lead Counsel for the Sovereign Legacy Council Former Socialist Federal Republic of Yugoslavia Belgrade, Zagreb, Sarajevo, Ljubljana, Skopje, Podgorica