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- [Commentator-2] based on ad revenue from web traffic or sponsors alone." Despite Founder-1's warning that Commentator-1 and Commentator-2 would not be profitable to employ, on or about February 14, 2023, Persona-1 informed Founder-1 that "[w]e would love to move forward with [Commentator-1 and Commentator-2]."
- On or about February 17, 2023, Founder-1 sent an email introducing Commentator-2 to "Eduard Grigoriann," Persona-1, and Persona-2. The parties arranged a call between Commentator-2 and "Eduard Grigoriann," which took place on or about February 22, 2023. In scheduling the call, Commentator-2 requested that "Eduard Grigoriann" call Commentator-2's cellphone. Instead, Persona-2 asked that the call take place on WhatsApp or Zoom. Both applications offer encrypted communications and the ability to place voice calls through voice-over-IP technology capable of obfuscating the physical location of a caller.
- On or about February 22, 2023, Founder-1 emailed Persona-1 that Founder-1 had spoken with Commentator-2, who was "happy with the licensing arrangement that was discussed" on Commentator-2's call with "Eduard Grigoriann." Founder-1 continued, however, that Commentator-2 "still would like to know more about the company and who he will be working with." Founder-1 added that Founder-1 had "assured [Commentator-2] that as we finalize the contract and begin working to put his show together and coordinate the launch, everyone will have time to get to know each other better and feel less like strangers!"
- On or about February 28, 2023, Founder-1 emailed Persona-1 that Founder-1 had spoken with Commentator-1, who would "like some material about Mr Grigoriann to learn a bit about who [Commentator-1 would] be working with." Founder-1 asked if there were "any links (press release, interviews, LinkedIn, profiles, etc) we can forward" Commentator-1 about "Eduard Grigoriann." On or about March 2, 2023, Persona-1 responded to Founder-1's email,
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