Sims

I. FACTUAL AND PROCEDURAL BACKGROUND

1 Plaintiff CleanFish, LLC, f/k/a Sig and Sour LLC, is a global seafood wholesaler and 2 importer. Dkt. No. 35 (“FAC”) ¶ 1. In April 2018, Plaintiff purchased CleanFish, Inc. through an 3 asset purchase agreement executed by Defendant Sims, who had co-founded CleanFish, Inc. in 4 November 2006 and was its authorized agent. Id. ¶¶ 17, 41. After the acquisition, Defendant 5 Sims continued to work for Plaintiff as a “key employee.” Id. ¶ 54. During this time, he allegedly 6 had “continued access to Plaintiff’s Confidential Data, which included client identities and internal 7 substantial analyses of customers’ product preferences, buying patterns, practices, and pricing.” 8 Id. 9 On or around May 17, 2019, Defendant Sims organized Buena Vista as a California 10 limited liability company. Id. ¶ 74. Plaintiff alleges that this was for the “sole purpose of directly 11 competing with Plaintiff in the retail and wholesale seafood distribution business.” Id. Defendant 12 Sims resigned from his employment with Plaintiff on May 31, 2019. Id. ¶ 75. Defendant Sims 13 then allegedly collaborated with Defendant ISF, an “established and primary…