9 COUNTY OF SANTA CLARA

12 GUZIK TECHNICAL ENTERPRISES, 13 Plaintiff, TENTATIVE RULING RE: DEMURRER AND MOTION TO 14 vs. STRIKE AMENDED COMPLAINT 15 KEYSIGHT TECHNOLOGIES, INC.,

16 Defendant.

21 I. INTRODUCTION

22 According to the Amended Complaint (“FAC”), filed on October 14, 2020, this case 23 arises out of defendant Keysight Technologies’ (“Defendant” or “Keysight”) tortious scheme to 24 defraud and steal valuable business opportunities from plaintiff Guzik Technical Enterprises 25 (“Plaintiff” or “Guzik”). (FAC, ¶ 1.) Under the guise of forming a partnership to develop and 26 sell high-bandwidth digitizer products, Defendant used a web of false promises, factual 27 misrepresentations, and fraudulent omissions to induce Plaintiff into developing a next- 28 generation digitizer product, but then breached all of its contractual promises, misused Plaintiff’s

1 confidential information and trade secrets to produce a competing product, and coerced Plaintiff 2 into accepting restric