Doe

I. BACKGROUND

A. CADA

CADA is an association of intermediate and high school activities directors, which seeks to promote the development of leadership through student activities. CADA has over 2300 members throughout California, most of whom work as teachers or school

2 administrators in intermediate or high schools. One way that CADA seeks to promote development of student leadership is by offering camps, programs and conferences for students and their advisors. At the camps and conferences that it hosts, CADA has featured speakers or “sponsors,” who appear for significantly reduced fees and in return are promoted to CADA’s members, who often hire them for local programs.

B. CADA’s Relationship with John Doe

1. Long-Term Association For more than three decades, CADA used and promoted Doe as a motivational speaker. According to Doe’s complaint, CADA began inviting him to speak as a featured speaker at its camps and conferences in 1994. As a result of these speaking engagements, Doe allegedly became a popular and well-known speaker whom many of CADA’s educator members hired to speak to students at local schools and programs. Indeed, according to Doe, CADA became his primary…