Olson

I. BACKGROUND

21 A. The Parties 22 The following factual background is taken from the complaint except if otherwise noted. 23 WFG is a multi-level marketing company that provides financial services via life insurance, 24 retirement strategies, and a variety of wealth-building strategies. First Amended Complaint 25 (“FAC”) ¶ 9, ECF No. 22. When an agent signs on to become affiliated with WFG, they are 26 encouraged to recruit additional agents, and they are compensated for sales of their recruits and 27 any sales by any agent that is brought on by that recruit. Id. ¶ 10. In or about 2013, Ms. Olson joined WFG and started working in the same hierarchy as Eric Olson (“Mr. Olson”). Id. ¶ 13. Ms. Olson signed an agreement with WFG (“the Agent Agreement”) which included multiple provisions that the Olsons contend are against California law. Id. ¶¶ 16–21 (the “Restrictive Covenants”). Beginning in about 2022, Mr. Olson expressed a desire to leave WFG, and he began discussing with WFG executives how best to leave WFG and sell or transfer, his “code,” which was his commission revenue stream from WFG. Id. ¶ 26. As of 2022, WFG had a policy that…