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D begin selling a product called a Dedicated Satellite Constellation (DSC) to foreign governments. D offered P a position as Senior Sales Manager. D offered P a low base salary with commissions of up to 15% (plus potential bonuses) for making sales of DSCs. P agreed to work for D. P executed an offer letter reflecting the above-referenced terms on July 6, 2021. Also attached to the Offer Letter was a Commission Plan (Commission Plan) outlining P's commission-based compensation structure. One of P's primary tasks was to help obtain a $6 million contract for the sale of DSCs to the Albanian government. P organized and made multiple visits to Albania, personally met with members of the Albanian government, up to and including the Prime Minister of Albania, and was the primary person responsible for presenting D's services to Albanian government officials. D also developed and maintained personal relationships with Albanian government officials and was heavily involved in negotiating D's contract with the Albanian government by attending meetings and providing additional briefings to Albanian officials. D repeatedly assured P that he was 'the lead' on this deal and that he would receive his contracted commission when the deal was signed. In March 2022, the Albanian government agreed, in principle, to terms regarding the purchase of DSCs. By June 2022, all necessary documents to complete the deal were submitted and awaiting execution by the Albanian government. P had 'completed all work necessary to earn his commission.' The complete formal necessities would delay formal execution of the deal for another several months. D terminated P on July 22, 2022, only months before the deal officially closed. P's termination was made without cause. In September 2022, D publicly announced that it had formally signed the deal-worth $6 million-with the Albanian government. D did not pay P any commission. P sued D for breach of contract. P claims that D breached the contract and violated the implied covenant of good faith and fair dealing by failing to pay the commission. D moved to dismiss the suit.

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