Hardell

BACKGROUND

I. Factual History

In 2019, Hardell founded Segmed, Inc., a medical data company, with three other Stanford alumni. Hardell became Segmed’s CEO and worked and resided in California until roughly March 2020, when she traveled to Colorado and remained as a resident. Vanzyl was a Blumberg senior director. Blumberg is a venture capital firm that invests in privately held portfolio companies, and Mohsen was and is the CEO of two companies in which Blumberg invested. Blumberg and Segmed are headquartered in California and both companies operate from California. In October 2020, Blumberg invested in Segmed. Pursuant to the investment agreement, Blumberg appointed Vanzyl to Segmed’s board of directors. Starting in summer 2021, Vanzyl directed Hardell to raise more funds for Segmed. He also assisted Hardell in her fundraising efforts, including with respect to a particular venture capital firm, dubbed “VC Firm A” in Hardell’s complaint. In January 2022, Vanzyl took Hardell to lunch in San Francisco, where he explained that “he was essential to Hardell’s and Segmed’s continued success,” and that if Blumberg expressed support for Segmed, other investors were more likely to…