Plaintiff, a Canadian citizen who was living in Canada at all relevant times, accepted an offer of at-will employment with defendant as an "Entry-Level Block-Chain Developer" working out of defendant's New York office. The offer letter, which was signed by plaintiff, set the start date as November 15, 2021, described the position as being of "immediate need," and conditioned the offer on, among other things, plaintiff's verification of his right to work in the U.S. In advance of the November 15th start date, plaintiff sought to obtain Trade NAFTA (TN) status, which "permits qualified Canadian and Mexican citizens to seek temporary entry into the United States to engage in business activities at a professional level" (U.S. Citizenship and Immigration Services, "TN NAFTA Professionals," [*2]https://www.uscis.gov/working-in-the-united-states/temporary- workers/tn-nafta-professionals [last accessed Mar. 11, 2025]). An application for TN status must include a letter from the applicant's prospective employer (hereinafter a TN letter) "detailing items such as the professional capacity in which [the applicant] will work in the United States, the purpose of [the applicant's] employment, [the applicant's] length of stay, and [the applicant's] educational qualifications" (id.). Following discussions with defendant, plaintiff prepared a TN letter himself and submitted it to U.S. Customs and Border Protection (USCBP), who rejected it and denied plaintiff entry to the U.S., causing plaintiff to miss the November 15th start date. After refusing plaintiff's request to provide an alternate TN letter, defendant rescinded its offer of employment to plaintiff. Plaintiff alleges that he thereafter hired an attorney, who sent defendant "a demand letter complaining of discrimination," and tha