De Leon v. Ricoh USA, Inc.

BACKGROUND

I. The Parties

23 Ricoh USA is corporation incorporated under Ohio law, with its headquarters and principal 24 place of business in Malvern, Pennsylvania. (Dkt. Nos. 1 at ¶ 9 & 29 at ¶ 9.) Ricoh USA is 25 26 1 Record citations are to material in the Electronic Case File (“ECF”); pinpoint citations are to the 27 ECF-generated page numbers at the top of the documents. authorized to do business in California. (Dkt. No. 29 at ¶ 9.) It produces, distributes, and services office equipment, including printers, photocopiers, and fax machines throughout the state. (Id.) IKON was an Ohio corporation before changing its name to Ricoh USA on April 1, 2012. (Dkt. No. 1 at ¶ 11; see also Dkt. No. 29 at ¶ 10 n.2.) Ricoh Americas was a Delaware corporation that merged into Ricoh USA on April 1, 2016. (Dkt. No. 1 at ¶ 13; see also Dkt. No. 29 at ¶ 11 n.3.) Plaintiff is a former Ricoh employee. (Dkt. No. 29 at ¶ 8(a).) He worked at the company’s Petaluma, California location “as a field service representative and technology service technician” from May 2000 to November 2017. (Id. at ¶ 8(a),(b).) II. Complaint Allegations …