Professional Documents
Culture Documents
US Equal Employment Opportunity Commission Vs Activision Blizzard
US Equal Employment Opportunity Commission Vs Activision Blizzard
US Equal Employment Opportunity Commission Vs Activision Blizzard
1
Case 2:21-cv-07682 Document 1 Filed 09/27/21 Page 2 of 7 Page ID #:2
2
Case 2:21-cv-07682 Document 1 Filed 09/27/21 Page 3 of 7 Page ID #:3
1 employees.
2 7. At all relevant times, Defendant Activision Publishing, Inc. has continuously been
3 a corporation doing business in the State of California, and continuously had at least 15
4 employees.
5 8. At all relevant times, Defendant King.com, Inc. has continuously been a
6 corporation doing business in the State of California, and continuously had at least 15
7 employees.
8 9. At all relevant times, Defendant Activision Blizzard, Inc. has continuously been
9 an employer engaged in an industry affecting commerce within the meaning of Sections 701(b),
10 (g), and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g), and (h).
11 10. At all relevant times, Defendant Blizzard Entertainment, Inc. has continuously
12 been an employer engaged in an industry affecting commerce within the meaning of Sections
13 701(b), (g), and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g), and (h).
14 11. At all relevant times, Defendant Activision Publishing, Inc. has continuously been
15 an employer engaged in an industry affecting commerce within the meaning of Sections 701(b),
16 (g), and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g), and (h).
17 12. At all relevant times, King.com, Inc. has continuously been an employer engaged
18 in an industry affecting commerce within the meaning of Sections 701(b), (g), and (h) of Title
19 VII, 42 U.S.C. §§ 2000e(b), (g), and (h).
20 13. All acts and failures to act alleged herein were duly performed by and attributable
21 to all Defendants, each acting as a successor, agent, alter ego, employee, indirect employer, joint
22 employer, integrated enterprise and/or or under the direction and control of the others, except as
23 specifically alleged otherwise. Said acts and failures to act were within the scope of such agency
24 and/or employment, and each Defendant participated in, approved and/or ratified the unlawful
25 acts and omissions by the other Defendants complained of herein. Whenever and wherever
26 reference is made in this Complaint to any act by a Defendant or Defendants, such allegations
27 and reference shall also be deemed to mean the acts and failures to act of each Defendant acting
28 individually, jointly, and/or severally.
3
Case 2:21-cv-07682 Document 1 Filed 09/27/21 Page 4 of 7 Page ID #:4
1 14. Plaintiff is ignorant of the true names and capacities of each defendant sued as
2 DOES 1 through 10, inclusively, and therefore Plaintiff sues said defendants by fictitious names.
3 Plaintiff reserves the right to amend the complaint to name each DOE defendant individually or
4 corporately as it becomes known. Plaintiff alleges that each DOE defendant was in some manner
5 responsible for the acts and omissions alleged herein and Plaintiff will amend the complaint to
6 allege such responsibility when the same shall have been ascertained by Plaintiff.
7
8 STATEMENT OF CLAIMS
9 15. More than thirty days prior to the institution of this lawsuit, on September 26,
10 2018, EEOC Commissioner Chai R. Feldblum signed Commissioner’s Charge Number 480-
11 2018-05212, initiating the EEOC’s investigation into the following allegations, including but not
12 limited to: “1. Subjecting female employees to sex-based discrimination, including harassment,
13 based on their gender. 2. Retaliating against female employees for complaining about sex-based
14 discrimination, based on their gender. 3. Paying female employees less than male employees,
15 based on their gender.”
16 16. Commission conducted an extensive investigation from September 26, 2018 to
17 June 15, 2021 of the allegations of sexual harassment and related retaliation against Defendants
18 and additional entities beyond the Charge, at their worksites in the United States. Defendants
19 cooperated in the investigation by providing information, documents, and testimony of
20 individuals necessary for the investigation.
21 17. On June 15, 2021, the Commission issued to Defendants a Letter of
22 Determination finding reasonable cause on the claims alleged in this Complaint.
23 18. As required by statute, the Commission invited Defendants to engage in
24 conciliation efforts to endeavor to eliminate the discriminatory practices and provide appropriate
25 relief. The conciliation process is statutorily required for the EEOC to address the findings made
26 in the Letter of Determination. The Commission engaged in extensive conciliation discussions
27 with Defendants, but the Commission was unable to secure through informal methods an
28 acceptable conciliation agreement.
4
Case 2:21-cv-07682 Document 1 Filed 09/27/21 Page 5 of 7 Page ID #:5
1 19. All conditions precedent to the institution of this lawsuit have been fulfilled.
2 20. At all relevant times, Defendants have been a company that creates and distributes
3 video games and other gaming-related content throughout the United States, with Activision
4 Blizzard, Inc., and Activision Publishing, Inc.’s principal places of business in Santa Monica,
5 CA and Blizzard Entertainment’s principal place of business in Irvine, CA.
6 21. Since in or around September 2016, there have been instances where Defendants
7 have engaged in unlawful employment practices in violation of §§ 701(k), 703(a) and 704(a) of
8 Title VII, 42 U.S.C. 2000e-2(a) and 2000e-3(a) by subjecting a class of individuals to sexual
9 harassment, to pregnancy discrimination and/or to retaliation.
10 22. Employees were subjected sexual harassment that was severe or pervasive to alter
11 the conditions of employment. The conduct was unwelcome and adversely affected the
12 employees. The Defendants knew or should have known of the sexual harassment of the
13 adversely affected employees.
14 23. Some employees complained about the sexual harassment, but Defendants failed
15 to take corrective and preventative measures. Once Defendants knew or should have known of
16 the sexual harassment of the adversely affected employees, Defendants failed to take prompt and
17 effective remedial action reasonably calculated to end the harassment.
18 24. Defendants discriminated against employees due to their pregnancy that adversely
19 affected the employees.
20 25. Defendants retaliated against employees who engaged in activity protected by
21 Title VII including, but not limited to, rejecting and/or complaining about sexual harassment
22 and/or complaining about pregnancy discrimination. As a result of engaging in such protected
23 activity, employees were subjected to adverse employment actions including discharge or
24 constructive discharge.
25 The unlawful employment practices complained of in paragraphs 20 to 25 above
26 adversely affected employees to suffer damages including emotional distress.
27
28
5
Case 2:21-cv-07682 Document 1 Filed 09/27/21 Page 6 of 7 Page ID #:6
6
Case 2:21-cv-07682 Document 1 Filed 09/27/21 Page 7 of 7 Page ID #:7