Zhang

I. BACKGROUND

A. FACTUAL ALLEGATIONS1

23 Li Rui was a prominent Chinese political figure and outspoken critic of the leaders 24 of the Communist Party of China until his death on February 16, 2019. First Am. Compl. 25 (“FAC”) ¶ 12, Dkt. 15; see also id. ¶¶ 13-15. Li Rui created personal diaries from at least 26 27 1 The parties are familiar with the underlying facts; only those matters pertinent to 1938 to 2019. Id. ¶ 16. He also maintained letters, photographs, and other materials, including but not limited to, diaries created by his first wife, Fan Yuanzhen, a diary created by both Li Rui and Fan Yuanzhen, and correspondence between Li Rui and Fan Yuanzhen (the physical copies of these materials and Li Rui’s personal diaries, exclusive of the intellectual property rights thereto, are referred to as the “Materials”). Id. ¶ 17. In February 1989, Li Rui visited Stanford and its Hoover Institution (“Hoover”). Id. ¶ 18. During the visit, he was shown some of Hoover’s China Collection. Id. According to Stanford, due to Hoover’s reputation for its holdings of twentieth century Chinese historical materials, Li Rui gave the Materials to…