Xu

I. BACKGROUND

23 Plaintiff Magic Leap, Inc. (“Magic Leap”) is a Delaware corporation with its principal 24 place of business in Plantation, Florida. Compl. ¶ 4. Plaintiff specializes in the field of “spatial 25 computing, which encompasses augmented, virtual and hybrid (or mixed) reality technology.” Id. 26 ¶ 2. Defendant Chi Xu (“Xu”) resides in Beijing, China. Id. ¶ 5. Defendant Hangzhou Tairuo 27 1 Technology Co., Ltd. (d/b/a “Nreal”), is a Chinese business entity established in or about early 2 2017. Id. ¶ 6. 3 Plaintiff alleges that Xu “formerly worked for Magic Leap in its Sunnyvale, California 4 facilities from July 27, 2015 until August 15, 2016.” Id. ¶ 5. As a condition of his employment, 5 Xu signed a Proprietary Information and Inventions Agreement (the “PIIA”), which “contains a 6 broad prohibition against the use or disclosure of the defined confidential and proprietary 7 information both during and after Mr. Xu’s employment” with Plaintiff. Id. ¶¶ 10–11; see id., Ex. 8 A (“PIIA”). Plaintiff further alleges that, during Xu’s employment with Plaintiff, Xu “had access 9 to much of Magic Leap’s Confidential Information spanning all…