White

BACKGROUND

I. The Operative Complaint

In July 2018, Smule and White discussed the possibility of White working for Smule. In these discussions, Smule said it had significant problems with its development process, it was not operating efficiently, and its lack of an experienced project manager had inhibited its growth. Smule stated that it needed an experienced project manager who could train, supervise, and recruit other experienced project managers; it wanted White to develop a functional project management team that would enable Smule to grow its business; and it wanted White to join Smule to reorganize the company’s project management operations and enable it to grow and operate more efficiently. Smule’s Vice President of Engineering, Alan Shang, elaborated: Shang needed a leader for project managers, and project teams and project responsibility need to be restructured; Shang hoped White could identify major deficiencies within 30 days and start bringing in competent personnel; Shang hoped reorganization would be substantially complete in one year, but understood it could take up to two years; and Shang wanted White to develop training protocols and manuals over the next…