The Court also finds Naderi's "failure to prevent" claim improper, as he has asserted it for the first time in his Opposition. See Gilmour v. Gates, McDonalds and Co., 382 F.3d 1312, 1315 (11th Cir. 2004) ("At the summary judgment stage, the proper procedure for plaintiffs to assert a new claim is to amend the complaint in accordance with Fed.R.Civ.P. 15(a). A plaintiff may not amend [his] complaint through argument in a brief opposing summary judgment."); accord Stanford Hosp. and Clinics v. Humana, Inc., 5:13-cv-04924 HRL, 2015 WL 5590793, at *6, (N.D. Cal. Sept. 23, 2015). The Court therefore need not consider it before granting summary judgment.