Page 13, E: The Conception and Formation of Defendant Bluehole
Throughout the developement of Lineage 3, Yong-Hyun Park ("Park"), the head of the project, repeatedly expressed to the company management dissatisfaction with his compensation. Although he was already one of the highest paid employees of the company, Park was of the opinion that he should receive additional salary as well as an equity interest in the future profits from L3. NCSoft management disagreed, believing that Park's compensation already generous by comparison with his peers both at NCSoft and at the competing Korean video game companies.

Unsatisfied with that response, Park began secret discussions with the other key managers from the L2 and L3 teams about leaving NCSoft, forming a new video game company, luring away the L3 development team, and using NCSoft's proprietary information to complete and launch, in effect, the same game they had been developing at NCSoft, while reaping a greater share of the profits for themselves. Park and the other managers entered into negotiations with potential third-party investors, to whom they disclosed NCSoft proprietary information about L3. After first failing to secure investment from a major Japanese competitor, the conspirators obtained backing from a wealthy individual.

The conspirators also were busy persuading many other L3 team members to resign collectively and join them in a new Korean game developer company -- an event referred to by Park as "D-Day". To that end, they so far as holding a meeting in a conference room of NCSoft to entice employees to join with them. Soon after, NCSoft became aware of this event and swiftly discharged Park and the other managers from their roles.
By that time, however, the damage was done. By March 2007, the efforts of Park and others proved successful - 48 of the more than 100 L3 team members left NCSoft to join the newly formed Bluehole. These individuals were selected based on their level of knowledge and information related to the L3 project and included game designers, programmers, and graphic artists. They were lured to Bluehole with attractive compensation packages that had been put together using confidential payroll and other personnel information taken from NCSoft.

>But the theft of proprietary information did not end there. As set forth in detail below, before departing NCSoft, Park and the other former managers and L3 team members systematically stole substantial quantities of valuable NCSoft technical trade secrets and other proprietary information related to the L3 game itself. Around the same time, NCSoft discovered the concerted theft through its internal investigation.