Lin

I. BACKGROUND

This case stems from Plaintiffs’ investment of $755,000 in an electronic data 24 security technology developed by Defendant Suavei. (Second Amended Complaint 25 “SAC” at ¶1). Defendant Suavei is described as an internet security company, founded in 26 2016. (SAC at ¶ 31). Suavei is a Delaware corporation with its principal place of 27 business in Las Vegas, Nevada. (SAC ¶ 23). Defendants Infante and Wong are the 28 cofounders and the only board members of Suavei. (SAC at ¶¶ 21, 22). Infante and Wong are residents of Nevada, and Plaintiffs are residents of California, New Hampshire, New York, and Texas. (SAC at ¶¶ 9-20). The security device in question is described as a self-configuring threat management solution for wirelessly connected devices (the “Technology”). (SAC at ¶31). The Technology purportedly includes SaaS-based architecture that uses machine learning algorithms to automate device identification and ongoing scans in corporate, industrial, and remote environments. (SAC at ¶ 32). Suavei advertises that the Technology rapidly assesses, finds and mitigates vulnerabilities in Critical Network Infrastructure, including 10 …