Todd

I. BACKGROUND

23 A. The Parties 24 The following facts are taken from the record. Where indicated, the court cites allegations 25 in the complaint to provide background information. Todd is a developer of cryptocurrency and 26 27 blockchain software. Compl. ¶ 15; Docket No. 24, Declaration of Peter Todd in Opposition to Motion to Strike (“Todd Decl.”) ¶ 2. He also works as an applied cryptography consultant. Compl. ¶ 1. Todd regularly speaks at conferences around the world regarding his work in cryptography. Id. ¶¶ 1, 17. He has a large online following, and regularly posts to his account on Twitter under the handle @peterktodd. Id. ¶ 19. Todd avers that he is “highly-regarded in the cryptography and cryptocurrency sectors” and that his reputation, including his online reputation, “are important aspects of his standing in the cryptography community and his ability to maintain his consulting profession.” Id. ¶¶ 16, 19. Lovecruft is a cryptographer and computer security expert. Lovecruft Decl. ¶ 2. They 9 provide “expertise and consultancy services to clients,” and attend and speak at conferences 10 centering around cryptography,…