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The following e-filed documents, listed by NYSCEF document number (Motion 001) 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38 were read on this motion to/for DISMISS. DECISION + ORDER ON MOTION In June 2022, plaintiff Damian Noto commenced this litigation against defendants Planck, LLC (d/b/a Patch Media), DMEP Corporation (d/b/a Hale Global), and Hawking LLC (d/b/a Market News International, or “MNI”), alleging that Patch Media (hereinafter, “Patch”) and owners of Hale Global agreed, but failed, to pay him commissions and additional equity in MNI for his expertise in the media industry. Based on these allegations, plaintiff has asserted six causes of action: (1) breach of contract; (2) violation of unspecified Labor Law provisions; (3) retaliation under Labor Law §215; (4) retaliation under the New York State Human Rights Law (“NYSHRL”); (5) retaliation under the New York City Human Rights Law (“NYCHRL”); and (6) quantum meruit. In mot. seq. 001, each of these causes of action are the subject of defendants’ motion to dismiss pursuant to, variously, CPLR 3211 (a) (5), and (a) (7). Plaintiff opposes the motion in its entirety. For the following reasons, defendants’ motion is granted in part. BACKGROUND In 2014, plaintiff began working for Patch Media in accordance with an employment agreement signed by the plaintiff and Charles Hale, Patch’s CEO and managing partner. (NYSCEF doc. no. 1 at 6, complaint; NYSCEF doc. no. 10, employment agreement.) The agreement provides for a base salary, a guaranteed bonus determined as a fixed percentage of said salary, and “10 fully vested Class C Unit(s) of equity in [Patch].” (NYSCEF doc. no. 10.) The agreement further describes plaintiffs employment as “at-will.” (Id.) According to plaintiff, after he began working for Patch, Charles Hale agreed to provide plaintiff with an additional 75 units of equity in the company, but Hale did not reduce this promise to a written document. (NYSCEF doc. no. 1 at 8.) In 2016, Warren St. John took over Hale’s duties as Patch’s CEO. Shortly thereafter, St. John sought plaintiffs expertise in increasing Patch’s advertising revenue and agreed to pay plaintiff a ten-percent commission on the gross revenue that Patch received from his “then existing and future sales and revenue partnerships he personally generated.” (Id. at 9.) Plaintiff alleges that he accepted this proposal, but St. John and Patch refused to provide written confirmation of the oral agreement for the commissions and later failed to tender the commissions owed. (Id. at

 
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