Zhou

I. BACKGROUND

18 Serenium, a start-up company with its operational headquarters in Palo Alto, California, 19 was founded to develop technology relating to diagnosis and treatment of sleep apnea. ECF 14, 20 First Amended Complaint (“FAC”) ¶ 1. Serenium claims that it was approached by Defendant 21 Jason Zhou (“Zhou”), a billionaire with interests in the British Virgin Islands, Cayman Islands, Hong Kong, and China. FAC ¶¶ 6, 56. Zhou is the CEO of Defendant New Century Healthcare Holding Co. Limited (“New Century”), which operates a number of hospitals in China. FAC ¶ 6. 25 The parties entered into negotiations regarding a potential business relationship, and, after a 26 meeting with New Century in Beijing, Serenium disclosed its proprietary technology pursuant to a 27 that it was “governed by Illinois law.” FAC ¶¶ 65. 1 During the course of the parties’ relationship, Zhou proposed that Serenium enter into a joint venture with Defendant Beijing Jiarun Yunzhong Health Technology Company Ltd. (“Beijing Jiarun”), which was held out as part of New Century. FAC ¶¶ 9, 86-88. Zhou claimed 5 that Beijing Jiarun did business as “Panda Pediatrics.” FAC ¶ 9.…