1. "From 2005 to 2013, Plaintiff OmniGen Research, LLC ('OmniGen Research') employed Defendant Yongqiang Wang as a scientist. Wang reported to Neil Forsberg, who is OmniGen Research's co-founder, and at the time was its Vice President and Chief Scientific Officer. In 2013, Wang worked as a consultant for Plaintiff Prince Agri Products, Inc. ('PrinceAgri'), which had become OmniGen Research's parent company as of December 20, 2012, with the acquisition of OmniGen Research by Prince Agri." (Compl. ¶ 1, ECF No. 1.)
2. "At the same time Wang worked for OmniGen Research and Prince Agri in Oregon, he breached his contracts with them by secretly creating an OmniGen Research-clone Chinese business based on stolen OmniGen Research and Prince Agri information and the infringement of their rights. That imitation business consists of at least two entities, Defendant Bioshen and the Chinese company Jiangsu Mirigen Biotechnology Development Co., Ltd. ('Mirigen')." (Compl. ¶ 2.)
3. "While working at OmniGen Research, Wang applied for a Chinese patent that covers a knockoff of an OmniGen product. He tried to hide the application from OmniGen Research and Prince Agri, even though it rightfully belongs to OmniGen Research, by having Defendant Yan Zheng—who is Wang's wife and . . . does not have a background in biological sciences—listed as an inventor in his place. He . . . tried to hide Bioshen by listing Zheng as its representative and 'Registrant/Owner' with the Oregon Secretary of State; and he . . . tried to hide Mirigen by having another associate, Wei Zeng, listed as the registrant, administrative contact, and technical contact for the Mirigen website." (Compl. ¶ 3.)
4. "A little more than a year after quitting OmniGen Research and Prince Agri, Wang published and took credit for OmniGen Research's product, product story and research approach as his own in a[n] ... article for a[n] ... overseas scientific journal. He continue[d] to use OmniGen Research information in marketing materials promoting Mirigen and Bioshen. And, in November 2015, he presented an OmniGen Research slide presentation as if it was his own at a large scientific conference in China. Many of the slides in that presentation were nearlyexact copies of the OmniGen Research slide presentation, altered only to add the Mirigen logo." (Compl. ¶ 4.)
5. "Mirigen and Bioshen market several lines of nutritional specialty products that are knockoffs of OmniGen Research's products." (Compl. ¶ 5.)
6. "Wang[] breach[ed] . . . two contracts with OmniGen Research and one contract with Prince Agri. Among other things, Wang has breached written agreements to return and not improperly use OmniGen Research's and Prince Agri's confidential information, to disclose and assign work-related inventions to OmniGen Research, to disclose work-related inventions to Prince Agri, and to not compete with Prince Agri." (Compl. ¶ 7.)
7. "Zheng and Bioshen intentionally interfered with OmniGen Research's and Prince Agri's economic relations with Wang because, among other things, they intentionally helped Wang breach his promises to assign his work-related patent applications and patents to OmniGen Research and to disclose them to both OmniGen Research and Prince Agri. Zheng and Bioshen intentionally interfered with Prince Agri's economic relations with Wang because, among other things, they intentionally helped Wang to breach his contract to not compete with Prince Agri." (Compl. ¶ 8.)
1. Omnigen Research And Prince Agri 8. "OmniGen Research, LLC is an Oregon limited liability company . . . OmniGen Research is a subsidiary of Prince Agri Products, Inc." (Compl. ¶ 13.)
9. "Prince Agri Products, Inc. is a Delaware corporation . . . Prince Agri is a subsidiary of Phibro Animal Health Corporation ('Phibro')." (Compl. ¶ 14.)
10. "In 2002, Forsberg and Steve Puntenney co-founded OmniGen Research when Forsberg was a professor at Oregon State University ('OSU'), and Puntenney was a graduate student in Forsberg's department. It is now a successful agricultural research and development company, operating within larger corporate entities following the sale of OmniGen Research by Forsberg and Puntenney to Prince Agri in December 2012. OmniGen Research has a research laboratory in Corvallis, Oregon and a research farm south of Corvallis." (Compl. ¶ 23.)
11. "OmniGen Research's business is based on technology originally developed by Puntenney. Puntenney had determined that the cause of a common disease, called Hemorrhagic Bowel Syndrome, in lactating cows was moldy feed. Puntenney developed feed additives that help counteract this cause, and that have a variety of other beneficial effects, including strengthening and helping to maintain dairy cows' immune system, which in turn helps to prevent diseases, reducing the need for antibiotics, and increasing milk production. Forsberg advanced the technology by among other things identifying mechanisms of action and immunological markers for better understanding it." (Compl. ¶ 24.)
12. "OmniGen Research holds numerous patents around the world, including in the U.S. and China. Prince Agri and Phibro have rights to use OmniGen Research's technology. Puntenney's and Forsberg's inventions led to breakthrough and highly successful products for dairy cattle, including OmniGen-AF, OmniGen-WYC and OmniGen-Green, which are developed, made and sold by Prince Agri, and also sold by Phibro. OmniGen Research has determined that its technology would benefit other species, including pigs and poultry." (Compl. ¶ 25.)
13. "The OmniGen products have had strong sales in the U.S. and elsewhere. Phibro has recently launched those products in China. Forsberg currently works as a consultant forPhibro, and is assisting with this product launch, including lecturing in China on scientific topics related to the OmniGen products." (Compl. ¶ 26.)
14. "Defendant Yongqiang Wang is a citizen of China, a legal permanent resident of the United States, and a resident of the State of Oregon, having his residence at 6255 SW Chestnut Drive, Corvallis, Oregon 97333." (Compl. ¶ 15.)
15. "Defendant Yan Zheng is a citizen of China, a legal permanent resident of the United States, and a resident of the State of Oregon, having her residence at 6255 SW Chestnut Drive, Corvallis, Oregon 97333. (Compl. ¶ 16.)
16. "Wang first met Forsberg when Wang was a graduate student at OSU and Forsberg was a professor. Forsberg took Wang under his wing, hiring him to work in his academic research laboratory. When OmniGen Research grew, Forsberg hired Wang in 2005 to work at OmniGen Research. Wang worked at OmniGen Research as Forsberg's right hand man for the next eight years." (Compl. ¶ 27.)
17. "Originally from China, Wang and his wife, Zheng, built lives in Corvallis, Oregon. With OmniGen Research as their sponsors, they became legal permanent residents of the U.S. They purchased their house and a rental property in Corvallis." (Compl. ¶ 28.)
18. "Wang apparently decided he owed no loyalty to OmniGen Research. So, while continuing to work at OmniGen Research, [Wang] . . . secretly form[ed] two businesses, Bioshen and Mirigen, to compete with OmniGen Research with the help of his wife and associates." (Compl. ¶ 29.)
19. "[Defendat] Bioshen is . . . registered as an assumed business name for Zheng with a principal place of business at 6255 SW Chestnut Drive, Corvallis, Oregon 97333." (Compl. ¶ 17.)
20. "Mirigen is a Chinese corporation. Mirigen's principal place of business is listed as Block 3, No. 28, Yanfeng Road, Yanqiao Supporting Area, Huisahn Economic Development Zone, Wuxi, China." (Compl. ¶ 32.)
21. "On or about February 6, 2012, while Wang still worked at OmniGen Research, Bioshen was registered as an assumed business name for a business with the Corporation Division of the Oregon Secretary of State using an electronic registration form bearing Zheng's electronic signature. The registration form listed Zheng as the business's 'Registrant/Owner,' and Wang's and Zheng's home address as its headquarters." (Compl. ¶ 30.)
22. "On or about April 28, 2012, the Bioshen website, www.bioshen.com, was registered, listing Zheng as the registrant but using Wang's email address and cell phone number for contact information." (Compl. ¶ 31.)
23. "On or about September 11, 2012, while Wang still worked at OmniGen Research, Mirigen was formed." (Compl. ¶ 32.)
24. "On or about October 21, 2012, the Mirigen website, www.mirigen.com, was registered, listing Zeng as the registrant, administrative contact, and technical contact." (Compl. ¶ 33.)
25. "Wang has been a co-owner of Mirigen from its inception, according to official Chinese documents." (Compl. ¶ 34.) Defendants did not dispute this allegation in their responsive pleading. (SAA ¶ 34.) Wang has maintained an ownership interest and hadinvolvement in Mirigen despite this Court's Preliminary Injunction prohibiting it, Exs. 6-7. (See ECF No. 104 at 7; Preliminary Injunction, ECF No. 50, ¶ 10 ("Wang and Zheng (including Bioshen) shall no longer have any involvement with or (direct or indirect) ownership interest in Mirigen.").
26. "Mirigen's website is mostly in...