Infineon Technologies, AG (defendant) created Qimonda AG (Qimonda), as a subsidiary. Infineon also created Qimonda North America Corporation and Qimonda Richmond LLC (Qimonda Subsidiaries). At the outset, Infineon owned 85 percent of Qimonda stock. This ownership was later reduced to 77.5 percent. Qimonda was unable to obtain independent financing given this ownership structure. However, Infineon initially provided Qimonda with 565 million EU in financing. Infineon also placed three of its own officers or board members in those positions within Qimonda. Infineon included Qimonda’s employees and earnings in its financial statements. Infineon used the term “Infineon Group” to refer to the combination of the entities, and stated that Infineon controlled the Infineon Group’s management and corporate functions. In fact, Infineon shared the provision of the following services, among others, with Qimonda: human resources, sales, facility management, legal, and accounting. When Qimonda AG’s business started to fail in 2008 and 2009, Infineon forced the Qimonda Subsidiaries to provide 87 percent of their revenue to Qimonda AG. Qimonda closed multiple facilities, and Blair (plaintiff) and other employees of the Qimonda Subsidiaries were laid off. Certain Qimonda employees were induced to waive their severance packages in exchange for employment at another facility, but Qimonda never fulfilled those relocation promises. Certain other employees were induced to take delayed severance, but Qimonda likewise did not honor those agreements. Blair sued Infineon and Qimonda AG, claiming that the layoffs violated various state and federal labor laws. Infineon filed a motion to dismiss based on its status as merely the parent of the Qimonda Subsidiaries.