Kalter

BACKGROUND

19 In March 2019, Plaintiff was hired at Keyfactor, Inc. as a district sales director. (Compl. 20 at ¶ 25). Plaintiff’s responsibilities included marketing and selling Keyfactor’s products 21 throughout the Midwest. Id. 22 Sometime in early 2019, Insight, a venture capital firm, invested approximately 77 23 million dollars in Keyfactor. (Id. at ¶ 28). Through that transaction, at least three Insight executives or officers obtained seats on Keyfactor’s Board of Directors. (Id. at ¶ 15). Insight also received power to hire and appoint executives at Keyfactor and gained management, oversight, input, or control over its operations. (Id. at ¶ 16) In May 2019, Insight appointed Keyfactor’s new chief executive officer. (Id. at ¶ 29). In August 2019, Keyfactor, with Insight’s approval, hired a new vice president of sales. (Id. at ¶ 31). After that, “various members of leadership at Keyfactor made comments reflecting the corporate preference for hiring younger employees.” (Id. at ¶ 33). In late 2019, Keyfactor reassigned several of Plaintiff’s accounts and sales territory to a younger sales manager. (Id. at ¶ 37). Plaintiff was then…