3 Complaint
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 male employees and potential employees at Google. 5.
Damore, Gudeman, and other class members were ostracized, belittled, and punished for their heterodox political views, and for the added sin of their birth circumstances of being Caucasians and/or males. This is the essence of discrimination—Google formed opinions about and then treated Plaintiffs not based on their individual merits, but rather on their membership in groups with assumed characteristics. 6.
Google employees and managers strongly preferred to hear the same orthodox opinions regurgitated repeatedly, producing an ideological echo chamber, a protected, distorted bubble of groupthink. When Plaintiffs challenged Google’s illegal employment practices, they were openly threatened and subjected to harassment and retaliation from Google. Google created an environment of protecting employees who harassed individuals who spoke out against Google’s view or the “Googley way,” as it is sometimes known internally. Google employees knew they could harass Plaintiffs with impunity, given the tone set by managers—and they did so. 7.
Google employs illegal hiring quotas to fill its desired percentages of women and favored minority candidates, and openly shames managers of business units who fail to meet their quotas—in the process, openly denigrating male and Caucasian employees as less favored than others. 8.
Not only was the numerical presence of women celebrated at Google solely due to their gender, but the presence of Caucasians and males was mocked with “boos” during company- wide weekly meetings. This unacceptable behavior occurred at the hands of high-level managers at Google who were responsible for hundreds, if not thousands, of hiring and firing decisions during the Class Periods. 9.
Plaintiffs bring this action to vindicate their legal rights, and to stop Google from repeating these practices against other employees or prospective employees now, and in the future.
THE PARTIES
10.
Damore is an individual who, at all times relevant to the Complaint, worked in Mountain View, California for Google as a Senior Software Engineer, a Software Engineer, and an Intern. Damore was an employee of Google from 2013 until his wrongful termination on August 7,