1. At all times relevant to this Complaint:
a. Company-I was a global technology company headquartered in Cupertino, California that designed, developed, and sold consumer electronics, computer software, and online services. Company-I was a publicly traded company whose securities were listed on the NASDAQ Stock Market. In terms of market capitalization, Company-I was consistently among the most valuable companies in the world.
b. Defendant GENE LEVOFF ("LEVOFF") was employed by Company-I at its headquarters in Cupertino. From in or around 2008 through in or around 2013, LEVOFF, an attorney, was the Director of Corporate Law at Company-I. From in or around 2013 through his termination in or around September 2018, LEVOFF was the Senior Director of Corporate Law at Company-I. In that role, LEVOFF functioned as the top corporate attorney at Company-1, reporting directly to Company-1 's General Counsel. Among other things, LEVOFF was responsible for overseeing Company-1 's compliance with securities laws, which included advising others regarding U.S. Securities and Exchange Commission (the "SEC") filings and financial reporting. In or around February 2018, Company-1 named LEVOFF its Corporate Secretary, a title he maintained until his termination. Before that, LEVOFF held the role of Assistant Secretary. From in or around September 2008 through in or around July 2018, LEVOFF served on Company-l's Disclosure Committee, and, as a result, had access to and obtained Company-1 's draft SEC filings and earnings materials before Company-1 disclosed its quarterly and yearly financial results to the public. LEVOFF served as one of the Disclosure Committee's cochairpersons from in or around December 2012 through in or around July 2018. . . .