Rosenzweig

FACTS

The facts are taken from the third amended complaint. Daniel Diermeier is described as “a renowned crisis and reputation management consultant.” He is a principal in Silicon Valley Innovation Institute, LLC (SVII). Plaintiff Russ Rosenzweig was the chief executive officer (CEO) of SVII. Rosenzweig has an interest in Launch Education, LLC, which in turn has an interest in SVII. Diermeier as an individual entered into a service agreement with Hari Vallurupalli as an individual and as manager of 63 Partners, LLC, and Paul Del Gallo as sole member of Three Companies, LLC. The agreement contained confidentiality and noncompetition clauses. The agreement also contained a provision giving the managers of 63 Partners and Three Companies the right to notify any present or prospective employer or client of Diermeier of their rights and obligations in their agreement with Diermeier. It also gave the managers the right to give notices to any present or prospective employer or client should Diermeier breach his obligations under the agreement. In February 2018, Del Gallo sent a notice by e-mail to 15 of Diermeier’s business associates, including his partners in SVII. It stated, “[This…