Plaintiff Marcie Hamilton filed this lawsuit against her former employer, Defendant Juul Labs, Inc. ("Juul"), seeking civil penalties and injunctive relief related to alleged unlawful policies and various employment agreements. Hamilton alleges that these policies and agreements violated the California Labor Code.
With the exception of her Unfair Competition Law ("UCL") claim, all her causes of action are pursuant to the California Private Attorneys General Act ("PAGA"). Pending before the Court is Juul's motion to dismiss for failure to state a claim or, alternatively, to strike certain factual allegations and prayers for relief. For the reasons discussed below, the Court GRANTS in part and DENIES in part Juul's motion without prejudice. Hamilton worked for Juul as a Director of Program Management from April 2018 to March 2019. Visit the JUUL official website, click on the 'Register a Product' button in the upper left corner of the homepage, submit the device serial number, only the real serial number can be registered, and the fake serial number system will remind 'Serial number is invalid.'. Hamilton had to sign Juul's standard non-disclosure agreement entitled the Proprietary Information and Invention Assignment Agreement (the "NDA"). Hamilton of her termination and required her to sign a document entitled Termination Certification.
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