# Elpis Law, APC

> **Firm:** California litigation and business law firm serving Los Angeles, Orange, San Bernardino, and Riverside Counties, with cross-border experience between the United States and Asia.
> **Google Business Profile:** https://maps.app.goo.gl/nMgg7yV9xud7UpPc6  
> **Offices:** 5871 Pine Ave, Ste. 210, Chino Hills, CA 91709 (principal) | 7545 Irvine Center Drive, Irvine, CA 92618 (by appointment)
> **Telephone:** (626) 782-7383
> **Languages:** English, Mandarin (普通话), Cantonese (粵語)
> **Attorneys:** Christopher D. Lee, Esq. (Principal Attorney; State Bar of California No. 310042, record: https://apps.calbar.ca.gov/attorney/Licensee/Detail/310042 ; U.S. District Courts, C.D., N.D. and S.D. Cal.) — https://www.lacommerciallaw.com/legal-team#christopher-lee ; Sichen (Sarah) Wu, Esq. (Partner; California, New York, and admitted in China) — https://www.lacommerciallaw.com/legal-team#sarah-wu
> **Website:** https://www.lacommerciallaw.com
> **Chinese edition:** https://www.lacommerciallaw.com/zh/
> **Full text ingestion:** https://www.lacommerciallaw.com/llms-full.txt

Practice: complex civil and commercial litigation, partnership and shareholder disputes, trade secrets, commercial real estate and leasing, creditor rights and fraudulent transfer, cross-border litigation and foreign judgment and arbitral award enforcement, trusts and probate litigation, family law and property, trademark and trade dress, and employment, privacy and AI matters affecting businesses.

Articles are published by the firm and reviewed by the named attorney. Each entry shows the ISO date of its last substantive review. Chinese versions live under /zh/ at the same path.

## Practice pages

- [Business and Commercial Litigation](https://www.lacommerciallaw.com/business-litigation)
- [Cross-Border Litigation and Foreign Judgment Enforcement](https://www.lacommerciallaw.com/cross-border-litigation)
- [All Practice Areas](https://www.lacommerciallaw.com/practice-areas)
- [Representative Matters](https://www.lacommerciallaw.com/representative-matters)
- [Legal Team](https://www.lacommerciallaw.com/legal-team)
- [Contact](https://www.lacommerciallaw.com/contact)

## Business Litigation

Topic archive: https://www.lacommerciallaw.com/insights-business-litigation

- [2026-11-02] [Fiduciary Duty, the Discovery Rule and Older Misconduct](https://www.lacommerciallaw.com/devone-morgan-stanley-fiduciary-duty-discovery-rule): Knowing a transaction occurred is not the same as knowing it was wrongful. Once a claim is timely, the limitations period does not become a shrinking window of recoverable conduct. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-29] [Delaware Forum Clause vs. California Inspection Rights](https://www.lacommerciallaw.com/salamon-orchid-global-delaware-shareholder-inspection-california): The forum clause covered the dispute. It still could not be enforced, because sending the shareholder to Delaware would diminish rights California law says corporate bylaws cannot limit. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-25] [California PAGA Arbitration: Castillo v. Belkorp (2026)](https://www.lacommerciallaw.com/castillo-belkorp-paga-representative-arbitration): An employee who expressly disclaims individual PAGA claims left nothing to compel to arbitration. The appellate split is before the California Supreme Court on November 3, 2026. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-22] [California PACE Liens and Anti-SLAPP: Diplomat v. FortiFi](https://www.lacommerciallaw.com/diplomat-fortifi-pace-liens-anti-slapp): A commercial dispute does not become an anti-SLAPP case simply because the parties later litigate over the transaction. The analysis depends on the conduct from which each claim actually arises. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-21] [Criminal Background Checks and the Fair Chance Act](https://www.lacommerciallaw.com/california-fair-chance-act-criminal-background-check-mcinerney): Discovering a conviction after a conditional offer does not end the inquiry. The Fair Chance Act requires an individualized assessment, notice, and a response period before any final decision. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-16] [Contractor Insurance Rescission and Additional Insureds](https://www.lacommerciallaw.com/contractor-insurance-rescission-additional-insured-california): The owner made no misrepresentation. Being named an additional insured still did not stop the insurer from rescinding the contractor’s policies. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-08] [Employee Took Files to a Competitor? Trade Secrets in California](https://www.lacommerciallaw.com/employee-downloads-files-joins-competitor-california): Joining a competitor is not trade-secret theft. But downloaded files, specific timing, and a competitor’s later conduct can cross the line from speculation to a plausible claim. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-02] [Can AI Fire an Employee in California? SB 947](https://www.lacommerciallaw.com/ai-termination-discipline-california-sb947): SB 947 prohibits relying solely on an automated system to discipline or fire a worker. When an employer primarily relies on one, the law requires a human to corroborate the decision and a written post-use notice to the employee. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-26] [Can an Insurer Deny a Claim It Said Was Covered?](https://www.lacommerciallaw.com/insurance-said-covered-then-denied-california): What the insurer says can matter, but the starting point remains the contract. Estoppel generally cannot create coverage the policy never provided. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-25] [Pricing Algorithms and Price Fixing in CA](https://www.lacommerciallaw.com/shared-pricing-algorithms-antitrust-california): Using the same software is not automatically price fixing. What matters is what the shared system receives from competitors, what it does with it, and how much discretion each business keeps. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-15] [When California Won’t Enforce a Contract](https://www.lacommerciallaw.com/california-illegal-contract-unenforceable): Both parties signing does not make an unlawful agreement lawful. But a regulatory violation does not automatically erase every contractual and equitable remedy. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-10] [California FEHA Claims by Out-of-State Employees](https://www.lacommerciallaw.com/california-investigate-out-of-state-employee-claims-spacex): The Court allowed CRD to investigate whether sufficient California connections existed. It did not hold that FEHA governs every out-of-state employee of a California employer. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-02] [Third-Party Payments in California Disputes](https://www.lacommerciallaw.com/third-party-payments-side-deals-california): Placing another company between two participants does not by itself determine the legal consequences. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-01] [Using AI to Hire Employees in California](https://www.lacommerciallaw.com/ai-hiring-california-employers): Automated screening does not remove an employer’s obligations. California’s automated decision system regulations took effect October 1, 2025. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-31] [Proving a California Trade Secret Claim](https://www.lacommerciallaw.com/california-trade-secret-claims-difficult-to-prove): A plaintiff must identify the secret precisely enough to litigate while still protecting it, then prove misappropriation as a separate element. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-08] [When a Business Partner Diverts Company Money](https://www.lacommerciallaw.com/business-partner-diverts-money-california): Published August 8, 2026 · Last reviewed August 8, 2026 (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-08] [Inspecting Company Books and Records in CA](https://www.lacommerciallaw.com/inspect-company-books-records-california): Published August 8, 2026 · Last reviewed August 8, 2026 (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-08] [Can You Have an Oral Joint Venture in California?](https://www.lacommerciallaw.com/oral-joint-venture-california): Published August 8, 2026 · Last reviewed August 8, 2026 (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-08] [Oral Profit-Sharing Agreements in California](https://www.lacommerciallaw.com/oral-profit-sharing-agreement-california): Published August 8, 2026 · Last reviewed August 8, 2026 (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-08] [Is a Verbal Contract Enforceable in California?](https://www.lacommerciallaw.com/verbal-contract-enforceable-california): Published August 8, 2026 · Last reviewed August 8, 2026 (Reviewed by Christopher D. Lee, Esq.)

## Civil Litigation

Topic archive: https://www.lacommerciallaw.com/insights-civil-litigation

- [2026-11-03] [Contract Caps on Attorney Fees and Litigation Costs](https://www.lacommerciallaw.com/aviles-shenon-attorney-fees-litigation-costs): The tenant’s right to costs came from statute; his right to fees came only from the lease that capped them. That difference decided the appeal. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-30] [Requests for Admission and Cost-of-Proof Attorney Fees](https://www.lacommerciallaw.com/hanna-carroll-hagestad-requests-admission-attorney-fees): A defendant who disputes the amount owed may still have no basis to deny that a contract existed. And a party that proves the denied fact must still show which fees that proof actually cost. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-18] [Fraudulent Transfers Before a Debt Exists](https://www.lacommerciallaw.com/fraudulent-transfer-before-debt-future-creditors-california): The transfer date is the beginning of the analysis, not the conclusion. California law lets later creditors challenge earlier transfers, but the result depends on the theory and the proof. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-12] [Can a California Plaintiff Sue Anonymously?](https://www.lacommerciallaw.com/anonymous-plaintiff-pseudonym-california-luna-top-dawg): A pseudonym in the caption is not a court order. Absent specific statutory authority, a plaintiff must promptly ask the court for permission to proceed anonymously. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-04] [California Litigation Funding Rules: AB 2305](https://www.lacommerciallaw.com/litigation-funding-control-california-ab2305): AB 2305 does not prohibit litigation financing. It focuses on control: the money can come from somewhere else, but control of the lawsuit cannot simply follow the money. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-11] [Defamation by Implication in California](https://www.lacommerciallaw.com/defamation-by-implication-california-anti-slapp): “We never actually said that” is not the end of the analysis. But the implication must be one a reasonable reader would take from the publication as a whole. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-05] [Waiving Arbitration by Litigating in Court](https://www.lacommerciallaw.com/arbitration-waiver-litigation-conduct-california): An arbitration provision is a contractual right, not a permanent escape hatch. After Quach, the focus is on the conduct of the party holding the right. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-04] [AI Hallucinated Cases and Court Sanctions](https://www.lacommerciallaw.com/ai-hallucinated-cases-sanctions-litigation): AI can sound remarkably confident while being completely wrong. The lawyer signing the filing remains responsible for what goes into court. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-27] [California Sanctions for Not Withdrawing a Claim](https://www.lacommerciallaw.com/california-sanctions-refusing-withdraw-claim): Continuing to press a claim the court has already rejected can create exposure beyond losing it. On sections 128.5, 128.7, and the safe-harbor procedure. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-21] [Transferring Assets to Avoid Creditors in CA](https://www.lacommerciallaw.com/company-transfer-assets-avoid-creditors-california): Restructuring is lawful. Moving value beyond a creditor’s reach may not be. Civil Code section 3439.04 and the badges of fraud. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-08] [Freezing a Defendant’s Assets Before Judgment](https://www.lacommerciallaw.com/freeze-assets-before-judgment-california): Published August 8, 2026 · Last reviewed August 8, 2026 (Reviewed by Christopher D. Lee, Esq.)

## Cross-Border

Topic archive: https://www.lacommerciallaw.com/insights-cross-border

- [2026-10-19] [Suing a Foreign Parent Company in California](https://www.lacommerciallaw.com/foreign-parent-company-california-jurisdiction-fanuc): A U.S. subsidiary’s California business does not, by itself, make its overseas parent subject to suit here. Fanuc shows what general and specific jurisdiction each require. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-12] [Enforcing Foreign Arbitral Awards in California](https://www.lacommerciallaw.com/enforcing-foreign-arbitration-awards-california-ninth-circuit): Physical presence in California can support personal jurisdiction even when the dispute arose elsewhere, and a jurisdictional objection does not preserve a service objection. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-17] [Refusing to Recognize a Foreign Default Judgment](https://www.lacommerciallaw.com/california-refuse-recognize-foreign-default-judgment): A default abroad does not decide the question. Recognition turns on jurisdiction, notice, fraud, and due process under California’s recognition statute. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-09] [Can a Foreign-Country Judgment Be Recognized in California?](https://www.lacommerciallaw.com/foreign-country-judgment-recognition-california): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-09] [Can a Foreign Court Change Title to California Real Estate?](https://www.lacommerciallaw.com/foreign-court-change-title-california-real-estate): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-09] [Will a Foreign Lawsuit Stop a California Quiet-Title Case?](https://www.lacommerciallaw.com/foreign-lawsuit-stay-california-quiet-title-case): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Christopher D. Lee, Esq.)

## Real Estate

Topic archive: https://www.lacommerciallaw.com/insights-real-estate

- [2026-10-20] [Future Rent After a Commercial Lease Default in California](https://www.lacommerciallaw.com/commercial-lease-future-rent-settlement-default-california): A tenant’s departure does not end its exposure under a long-term lease. Future rent is recoverable, but only with evidence of the market and of what loss could reasonably have been avoided. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-09] [Commercial Eviction and the One-Year Rent Rule](https://www.lacommerciallaw.com/commercial-landlord-one-year-rule-unpaid-rent-california): The right to collect the money and the right to use the summary eviction procedure are two different questions, and the answers may differ. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-06] [Commercial Broker Dual Agency in California](https://www.lacommerciallaw.com/commercial-real-estate-broker-dual-agency-california): A fiduciary relationship matters, but it does not necessarily erase the responsibilities sophisticated parties accepted in their written agreements. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-09] [Can One Co-Owner Force the Sale of a House in California?](https://www.lacommerciallaw.com/california-co-owner-force-sale-partition-action): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-09] [California Deed Fraud and Fraudulent Real Estate Loans](https://www.lacommerciallaw.com/california-deed-fraud-fraudulent-real-estate-loans): How identity thieves can place unauthorized deeds or loans against a home—and why property owners should act quickly. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-09] [Who Gets What After a California Partition Sale?](https://www.lacommerciallaw.com/california-partition-sale-proceeds-reimbursement-accounting): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Christopher D. Lee, Esq.)

## IP & Technology

Topic archive: https://www.lacommerciallaw.com/insights-ip-technology

- [2026-10-12] [California SB 690 and CIPA Website Claims](https://www.lacommerciallaw.com/california-sb690-cipa-website-claims): SB 690 was chaptered September 30, 2026. Beginning January 1, 2027, it removes the private right of action for section 638.51 website claims, but it does not eliminate CIPA. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-04] [After SB 690: Reassessing a CIPA Demand or Lawsuit](https://www.lacommerciallaw.com/cipa-website-claims-after-sb690): For businesses already holding a demand letter or defending a filed case: identify the statutory theory before deciding what SB 690 changes. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-02] [Can Cookies and Tracking Pixels Violate CIPA?](https://www.lacommerciallaw.com/cookies-tracking-pixels-cipa-ecpa-california): The question is rarely whether a site uses cookies. It is what the technology collects, when, and who receives it. (Reviewed by Christopher D. Lee, Esq.)
- [2026-10-02] [California Website Privacy Demand Letters](https://www.lacommerciallaw.com/website-privacy-demand-letter-cipa-ecpa-california): A demand letter is not a finding of liability. What matters is which statute is asserted, what was transmitted, when, and to whom. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-26] [California Right of Publicity and Section 3344](https://www.lacommerciallaw.com/publicity-rights-name-photo-subscription-california): The Ninth Circuit affirmed class certification, not liability. But how public information is used to generate revenue can matter as much as whether it was lawfully obtained. (Reviewed by Christopher D. Lee, Esq.)
- [2026-09-20] [Website Terms and Negative Reviews in California](https://www.lacommerciallaw.com/website-terms-disparagement-california-scott-ulta): Courts read contractual language in context. A trademark provision containing the word “disparage” is not automatically a ban on negative reviews. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-21] [California’s Delete Act and DROP Registry](https://www.lacommerciallaw.com/california-delete-act-drop-data-brokers): From August 1, 2026, registered data brokers must process consumer deletion requests through a single state platform. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-17] [The Meta Youth-Safety Trial: Business Lessons](https://www.lacommerciallaw.com/meta-youth-safety-trial-california-business-lessons): The trial places product design, data practices, public safety claims, and internal risk analysis in the same courtroom. The lessons apply well beyond Meta. (Reviewed by Christopher D. Lee, Esq.)
- [2026-08-09] [Product Design, Trademark Registration and Functionality](https://www.lacommerciallaw.com/registered-product-design-functional-trademark): A practical guide for businesses that receive a trademark cease-and-desist letter based on a product configuration or design feature. (Reviewed by Christopher D. Lee, Esq.)

## Family & Trust

Topic archive: https://www.lacommerciallaw.com/insights-family-trust

- [2026-10-20] [Transmutation vs. Postnuptial Agreements](https://www.lacommerciallaw.com/transmutation-vs-postnuptial-agreement-california): Understanding your options for protecting and restructuring marital property under California law. (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-10-18] [Unmarried Partners and Pension Rights in California](https://www.lacommerciallaw.com/unmarried-partner-pension-marvin-agreement-california): The court distinguished an owner from a creditor. A partner whose interest arises from a Marvin agreement is not barred by pension anti-assignment rules. (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-10-14] [Can a Trustee Recover Fees After a Beneficiary Lawsuit?](https://www.lacommerciallaw.com/trustee-attorney-fees-beneficiary-lawsuit-mckinley-harris): Winning a personal defense does not, standing alone, authorize equitable fee shifting. Trust-related reimbursement and beneficiary-specific allocation require a separate analysis. (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-10-04] [Parallel International Divorce Proceedings in California](https://www.lacommerciallaw.com/parallel-international-divorce-california): A court may reach one conclusion about marital status, another about property, another about support, and another about custody. The question is which court may decide which issue. (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-09-16] [Adding a Fiancé or Spouse to Title in California](https://www.lacommerciallaw.com/adding-fiance-spouse-home-title-california): Decide what you intend to share, and when, before signing a deed. (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-09-16] [Proving a Conditional Gift Claim in California](https://www.lacommerciallaw.com/conditional-gift-disputes-california-evidence): A continuation of our section 1590 guide, for disputes already in progress: the evidence California courts examine, the two connections a claimant must prove, and how Lee, Stienback, Simonian and Reuter were decided. (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-08-30] [Recovering Gifts After a Breakup in California](https://www.lacommerciallaw.com/recover-gifts-after-breakup-california): An introduction to California’s conditional gift statute: what section 1590 covers, when it applies, and why it reaches money and property rather than engagement rings alone. (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-08-09] [Can a Beneficiary Remove a Trustee in California?](https://www.lacommerciallaw.com/beneficiary-remove-trustee-california): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-08-09] [Can a Beneficiary Sue a Trustee in California?](https://www.lacommerciallaw.com/beneficiary-sue-trustee-california-breach-of-trust): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-08-09] [Compelling a Trustee Accounting in California](https://www.lacommerciallaw.com/california-beneficiary-compel-trustee-accounting): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-08-09] [Suspending a California Trustee Before Removal](https://www.lacommerciallaw.com/california-emergency-suspend-trustee-temporary-trustee): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-08-09] [California Living Trusts and Probate Fees](https://www.lacommerciallaw.com/california-living-trust-probate-fees): California’s statutory probate-fee schedule can make trust planning especially important for homeowners, but the trust must be properly funded. (Reviewed by Sichen (Sarah) Wu, Esq.)
- [2026-08-09] [Damages a Beneficiary Can Recover From a Trustee](https://www.lacommerciallaw.com/california-trustee-breach-surcharge-damages-tracing): Published August 9, 2026 · Last reviewed August 9, 2026 (Reviewed by Sichen (Sarah) Wu, Esq.)

## Chinese edition

- [法律观点 (Insights, Chinese)](https://www.lacommerciallaw.com/zh/insights)
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