Abramowitz

I. BACKGROUND

19 A. Factual Background 20 Palantir is a data analytics company that was founded in 2003. Fifth Am. Compl. (“5AC”) 21 ¶¶ 1, 16-17, ECF 126. To preserve its competitive advantage, Palantir allegedly places great 22 emphasis on maintaining the secrecy of its proprietary information, and therefore its trade secrets 23 constitute some of its most valuable assets. 5AC ¶¶ 2, 20. For example, Palantir allegedly restricts 24 access to its sensitive internal information to employees with proper authorization and who need 25 the information to perform their jobs. 5AC ¶ 20. Palantir also allegedly monitors its network for 26 potential risks and protects its networks from unauthorized access. 5AC ¶ 20. Additionally, 27 information to sign confidentiality agreements. 5AC ¶¶ 21-22. Marc Abramowitz is a private investor with no technical or engineering background. 5AC ¶¶ 3, 24. He became interested in Palantir in 2005, and he invested in the company through KT4 and the Trust, “two entities Abramowitz controls and uses to make investments and hold interests in companies with new or emerging technologies.” 5AC ¶¶ 3, 24. KT4 is a limited liability …