Hoffman

I.

FACTUAL AND PROCEDURAL BACKGROUND1

A. The Underlying Action

In its complaint, Quidel alleges that it is in the business of "developing,

manufacturing and marketing point-of-care . . . diagnostic tests for the detection and

management of a variety of medical conditions and illnesses." As part of this business,

the complaint further alleges, Quidel places great importance on its proprietary,

confidential and trade secret information — including its technological advances,

products and pricing information, competitive strategies and internal business plans —

taking care to safeguard this information and to prevent its disclosure by closely

managing who has access to confidential, proprietary and trade secret information.

As pertinent to the issues in this writ proceeding, Quidel avers that it hired

Hoffman in July 2006 and that Hoffman left Quidel's employ in May 2013 in order to

work for BD, one of Quidel's "main direct competitors."2 During the time Quidel

employed Hoffman, according to the complaint, Hoffman received regular promotions,

ultimately holding the position of "Associate Director in Quidel's Molecular Diagnostic

Given the…