Huang

I. Background

20 Plaintiff Genzon Investment Group Co., Ltd., is a corporate entity created and 21 based in Peoples’ Republic of China. Shuyang Genzon Novel Materials Co., Ltd., 22 (“Shuyang Genzon”) is a Chinese corporate entity created by plaintiff for purposes of the 23 agreements at issue, and it is not a party to this lawsuit. 24 Defendant Bin Huang is a natural person residing in Fremont, CA. Huang and his 25 wife, Xin Xing Wang, together own defendant Molecon, Inc., a corporation registered in 26 California and headquartered in Fremont. Molecon Suzhou Novel Materials Co., Ltd., 27 (“Molecon Suzhou”) is a Chinese corporation owned by Huang that is involved with the agreements at issue, but it is not a party to this lawsuit. Plaintiff aimed to utilize Huang’s purported expertise to produce biodegradable greenhouse film, but the material produced did not meet desired standards. The material fell apart, tore open, or collected excessive condensation. Plaintiff reports facing many lawsuits because of these defective products. Collaboration Agreement On October 25, 2017, plaintiff, defendant Huang, defendant Molecon, Inc., and …