2 Complaint

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James Damore (“Damore”) and David Gudeman (“Gudeman” (together, “Plaintiffs”), through their attorneys, Dhillon Law Group Inc., file this Complaint against Google, LLC. (“Google”), a Delaware limited liability company, and DOES 1-10 (Google and Does, collectively, “Defendants”). Upon personal knowledge, or, if so indicated, upon information and belief, P laintiffs allege as follows:

CASE SUMMARY

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Plaintiffs bring this individual and class action on behalf of themselv es and on behalf of a class and subclasses defined as all employees of Google discriminated against (i) due to their perceived conservative political views by Google in California at any time during the time period beginning four years prior to the filing of this Complaint through the date of trial in this action (“Political Class Period”); (ii) due to their male gender b y Google in California at any time during th e time period beginning one year p rior to the filing of this Complaint through the date of trial in this action (“Gender Class Period”); and/or (iii) due to their Caucasian race by Google in California at a ny time during the time period beginning one year prior to the filing of this Complaint through the date of trial in this action (“Race Class Period”) (Political Class Period, Gender Class Period, and Race Class Period referred to collectively, as “Class Periods”). These violations also subject Google to claims for violation of California’s Business and Professions Code section 17200

et seq.

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Throughout the Class Periods, and in violation of California law, Google employees who expressed views deviating from the majority view at Google on political subjects raised in the workplace and relevant to Google’s emplo yment policies and its business, such as “diversity” hiring policies, “bias sensitivity,” or “social justice,” were/are s ingled out, mistreated, and systematically punished and terminated from Google, in violation of their legal rights. 4.

Google’s open hostility for conservative thought is paired with invidious discrimination on the basis of race and gend er, barred by law. Google’s management goes to extreme—and illegal—lengths to encourage hiring managers to take protected categories such as race and/or gender into consideration as determinative hiring factors, to the detriment of Caucasian and

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