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Case Study Memo-Google LLC

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Raymond B. Chiu wrote this case under the supervision of Professor Fernando Olivera solely to provide material for class
discussion. The authors do not intend to illustrate either effective or ineffective handling of a managerial situation. The authors may
have disguised certain names and other identifying information to protect confidentiality.

This publication may not be transmitted, photocopied, digitized, or otherwise reproduced in any form or by any means without the
permission of the copyright holder. Reproduction of this material is not covered under authorization by any reproduction rights
organization. To order copies or request permission to reproduce materials, contact Ivey Publishing, Ivey Business School, Western
University, London, Ontario, Canada, N6G 0N1; (t) 519.661.3208; (e) cases@ivey.ca; www.iveycases.com.

Copyright © 2018, Ivey Business School Foundation Version: 2018-11-05

It was a rude welcome for the newly hired vice-president of diversity, Danielle Brown, at Google LLC
(Google). Just over a month into her new job, Brown was confronted by an internal memo, posted by
Google engineer James Damore, espousing his views on the causes of gender disparities and problems
with the company’s diversity programs. Damore’s memo was leaked to the public and he was fired two
days later. The chain of events set off one of the most publicized controversies in the firm’s history. The
incident brought chief executive officer (CEO) Sundar Pichai back from vacation and led to a high-level
decision focused on protecting Google’s public image and employees’ well-being. Corporate
communication with Damore was brief, and the unrest had a chilling effect on what would otherwise have
been Brown’s impressive transition as an up-and-coming high-tech executive.

Damore’s memo provoked a dizzying array of viewpoints within the company and, once public, within
the media. With the turmoil showing little sign of abating, Damore’s memo reminded many women of the
hurt they had experienced from discrimination and harassment. The company’s reaction also left many
employees who held unpopular views frightened that they too could be targeted. Brown had to find a way
to move people past debates over Damore and his memo. It was an opportunity to demonstrate the
candour and character that could help her team regain hope, set an example for others, and build trust in
her and in the company. In a circumstance where communication and relationships had become fractured,
her leadership would now be defined by how she chose her words in the wake of the crisis.


Brown was appointed Google’s new vice-president of diversity, integrity, and governance in 2017. She arrived
on the job just over a month before the Damore crisis broke in August 2017.2

In 2009, Brown was one of 15 master of business administration graduates nationwide who were accepted
into the accelerated leadership program at Intel Corporation (Intel). Showing the versatility that allowed
her to excel as a management consultant, sales manager, and product marketer in her early career, Brown
rose to chief of staff of global human resources (HR) within four years, was appointed chief diversity and
inclusion officer just a year later, then vice-president of global HR three years after that.3

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Although the Intel appointment was the first diversity and inclusion role in Brown’s career, she boasted a
record that exceeded the company’s goals for diversity hiring. She had achieved stretch goals for hiring and
retention, weekly reporting, transparent metrics, engagement of majority males, a complaint hotline, and
confrontation of offenders.4 In 2015, when Brown had less than a year in the diversity role, Intel’s CEO
announced an investment of US$300 million over five years in diversity efforts. Brown’s value proposition
was a culture where a “diverse range of perspectives and views” enabled business success. Intel boasted an
“open door policy” that encouraged dialogue between employees regardless of their respective levels, at
times holding executives to account when they ignored concerns of others.5


James Damore was a senior software engineer in Google’s search division. He joined Google in 2013
with an extensive academic background in biology and computational biology and a reputation for
competitive participation in chess and strategy games. He worked his way up to the project leader level,
which merited him a salary in the US$300,000 range.6

In June 2017, after what he considered unpleasant experiences with Google’s internal culture and
diversity programs, Damore began typing his thoughts during a long business flight to China. Titling his
memo “Google’s Ideological Echo Chamber,” Damore wrote in response to invitations from diversity
program organizers to provide feedback. He submitted his memo in early July, eager to hear a response.
When he did not receive a reply, Damore posted his memo through internal lists and forums.7

Early on August 5, 2017, online news outlets reported that Damore’s memo had gone “viral” among
Google employees the day before. The same day, the memo was picked up and posted by a public
website; labelled an “anti-diversity manifesto,” the memo immediately attracted widespread attention.8

Damore described his experience of diversity training as one in which he was shamed and restricted from
voicing unwelcomed ideas.9 Google fired Damore on August 7, two days after the leak, with no apparent
link between the decision to fire him and Brown’s responsibilities as diversity officer.

After he was fired, Damore attracted an instant following, gaining 35,000 followers on his Twitter Inc.
account and inspiring an organization of protests across the country—which were later cancelled due to
alleged terrorist threats. Damore first accepted online interviews with right-wing media outlets to avoid
hostility from media unsympathetic to his views.10

In an op-ed in the Wall Street Journal, Damore complained about the lack of “open and honest
discussion” and his experience that employees’ identities were wedded to the company “almost like a
cult.” In online question-and-answer sessions, Damore expressed his disappointment over being
“shamed” by his supervisor before the memo was leaked, and he emphasized that his intention was not to
attack others but to improve Google’s culture. Damore did not apologize for his memo or for upsetting
others, and he still believed his views were correct.11


Damore prefaced his 10-page document with a statement affirming that he valued diversity and inclusion,
recognized the existence of sexism, and disapproved of stereotyping individuals, emphasizing the need to
stay focused on “population level differences in distributions.” In places throughout the memo, he also
alluded to the possibility of bias and limitations in his perspective, and the need for “open and honest”
discussion to address gender and ideological issues in the company.12

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Damore began his memo by suggesting that the left and right biases that may be hindering discussion at
Google were the “result of deep moral preferences,” (a reference to Jonathan Haidt’s well-regarded
research on moral foundations). He then proposed several non-socially constructed causes of the gender
gap in technology (tech), specifically software engineering, focusing on differences in biological and
personality traits. He covered a range of purported “non-bias [sic] causes,” including prenatal exposure to
testosterone, differing interest in people versus things, levels of the personality traits extraversion and
neuroticism (referred to by Damore as “higher anxiety, lower stress tolerance” and by psychologists in the
positive sense as emotional stability), and differences in drive for status. Based on the differences he
discussed, Damore concluded that “principled” and “optimizing” approaches to diversity were preferable
to “arbitrary social engineering” (hiring quotas). He proceeded to list existing Google practices that he
considered “discriminatory,” including programs exclusively for “a certain gender or race,” special
queues and treatment for such candidates, scrutiny of insufficiently diverse groups, and any practices or
goals that could result in inappropriate incentives or illegal double standards.13

In the next section of his memo, Damore reiterated the importance of recognizing ideological biases—
possibly veiled left or Marxist-style biases—that he believed “increase race and gender tensions” because
they affect how the social sciences are studied and maintain “myths like social constructionism and the
gender wage gap.” He identified other consequences of these biases as overprotection of females,
dismissal of gender issues affecting men, and “extremely sensitive PC-[politically correct] authoritarians”
who engage in “violence and shaming.”14

Damore proposed “non-discriminatory ways” to address the gender gap, including making software
engineering more people-oriented, allowing co-operative behaviour to thrive, and reducing stress and
increasing flexibility in tech and leadership work. With the overall goal of restoring psychological safety and
stopping discriminatory practices, Damore ended his memo with a range of suggestions to reduce the level
of intolerance, moralization, alienation, and hostility, including the reduction of over-empathetic support for
the suffering and offences of select groups. He believed that discriminating merely to increase representation
of women in tech was misguided and costly, causing the same poor outcome as failed attempts to address
problems with “the homeless, work-related and violent deaths, prisons, and school dropouts.”15


Corporate Responses

Responses from numerous internal and external stakeholders poured in once Damore’s memo had been
posted. Before the memo was leaked to the public, Ari Balogh, vice-president of engineering and
Damore’s supervisor, wrote an internal memo stating that “Questioning our assumptions and sharing
different perspectives” was an important part of Google’s culture, but “one of the aspects of the post that
troubled me deeply was the bias inherent in suggesting that most women, or men, feel or act a certain
way. That is stereotyping, and it is harmful.”16

The day Damore’s memo was leaked to the public, Brown responded in an internal memo to all staff (see
Exhibit 1), saying,

Part of building an open, inclusive environment means fostering a culture in which those with
alternative views, including different political views, feel safe sharing their opinions. But that
discourse needs to work alongside the principles of equal employment found in our Code of
Conduct, policies, and anti-discrimination laws.17

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The day after firing Damore, Pichai wrote to employees (see Exhibit 2), declaring,

We strongly support the right of Googlers to express themselves, and much of what was in that
memo is fair to debate, regardless of whether a vast majority of Googlers disagree with it.
However, portions of the memo violate our Code of Conduct and cross the line by advancing
harmful gender stereotypes in our workplace.18

Co-Worker Responses

Co-worker responses to the memo were openly critical, calling for Damore to be fired. According to
Damore, these were calls for “censorship, retaliation and atonement.” Various voices labelled the memo
“screed,” “pure toxicity,” “garbage fire,” “bigoted,” “misogynist,” and “violently offensive.”19 Facilitated
by Google’s collaborative communication platforms, attacks directed at Damore and open messages to
Brown effectively put both on trial. Leaked posts revealed that many of these communications were from
middle-level managers, using expletives to describe Damore and the memo, refusing to work with his
department, questioning his competence to sit on hiring committees, blaming him for attrition of
employees, and expressing intentions to silence and banish anyone sympathetic to Damore. Some posts
openly disparaged Brown for not issuing a more severe criticism of the memo.20

Numerous women publicly expressed their disappointment and disgust with Damore’s memo, and some
were motivated by the controversy to look for work elsewhere.21 One female employee expressed that the
memo was not considerate of women’s views and feelings and that the public response was too focused on
freedom of speech issues and a debate about reasons for termination. “To have us all lumped into one sort of
category like that,” she said, “and to have such a baseless claim made about who we are, and to have it
positioned as fact—as scientific fact—I don’t know how we could feel anything but attacked by that.”22

Using words like “unlawful” and “hostile,” Susan Wojcicki, CEO of Google’s YouTube, criticized the
memo for perpetuating negative stereotypes and unfounded biases that would now be exposed to a new
generation, hindering efforts to deal with a gender gap that existed in tech but not in other science,
technology, engineering, or mathematics (STEM) fields. Expressing her alarm over what she believed
were unacceptable comparisons between people, she posed the question, “What if the memo said that
biological differences amongst black, Hispanic, or LGBTQ (lesbian, gay, bisexual, transgender, queer or
questioning) employees explained their underrepresentation in tech and leadership roles? Would some
people still be discussing the merit of the memo’s arguments or would there be a universal call for swift
action against its author?”23

Few media articles covered employees who supported Damore, due in part to the employees’
unwillingness to speak out except by leaking messages written by other employees who engaged in
defamation and threatened to blacklist those they labelled as “anti-diversity.”24 However, one reporter
who spoke to employees anonymously found a range of viewpoints, including some that agreed that the
culture maintained its control by “shaming dissenters into silence.” The employees noted that the practice
of shaming Damore publicly indicated that critics preferred to dominate the public discourse rather than
to engage him in direct discussion. Through the anonymous corporate chat application, Blind, a Google
employee complained about the “terrifying” discovery that “if someone is not ideologically aligned with
the majority then he’s labelled as a ‘poor cultural fit’ and would not be hired/promoted.” Others
applauded Damore’s courage and found it hypocritical to talk about diversity and inclusion and then
exclude divergent opinions.25

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To shed light on Damore’s claim that “there were many women who were empowered and that agree with
me,”26 Blind conducted a survey of 4,000 employees across Silicon Valley. The results showed that
44 per cent of Google respondents were in support of firing Damore, a result that placed the response
from Google employees in the middle of similar responses from within other tech firms (see Exhibit 3).27

Public Responses

The negative response to Damore’s memo was unreserved. Megan Smith, formerly vice-president at Google
and, at the time, a chief technology officer of the United States, was glad that Damore’s views were now out
in the open to condemn. She called the memo “insidious . . . death by a thousand paper cuts . . . they are
misguided, they’re destructive to their colleagues.” Former Google engineer Erica Baker criticized Google
for allowing an environment in which “racists and sexists feel supported and safe in sharing these views in
the company.”28 Angela Saini, science journalist and author of Inferior: How Science Got Women Wrong,
argued that psychological studies showed the “tiniest gaps, if any, between the sexes, including areas such as
mathematical ability and verbal fluency,” and said that brains could not be distinguished by sex.29 Cynthia
Lee, computer science professor at Stanford University, believed that Damore’s “quasi-professional” but
dangerously “beguiling” scientific arguments were a “red herring,” distracting attention away from the
“glaring evidence, in individual stories and in scientific studies, that women in tech experience bias and a
general lack of a welcoming environment, as do underrepresented minorities.”30

Multiple outlets expressed their disapproval of Damore’s dismissal. Their concerns were based on the view
that he was mainly expressing an opinion about how diversity could be improved based on findings that
were unquestioned among those who studied basic gender differences.31 A few female commentators were
less alarmed by the gender differences in tech. Megan McArdle, a policy journalist and former technology
consultant, found that her male co-workers showed a passion for technology that was not often shared by
their female counterparts. McArdle was matter of fact about being in the minority around men even though
the environment was naturally and regrettably less hospitable when representation was lopsided.32

A poll conducted by the Center for American Political Studies at Harvard University and The Harris Poll
found that 55 per cent of respondents said Google was wrong to fire Damore. The respondents were
divided within their political groups, with 50 per cent of Democrats, 56 per cent of independents, and 61
per cent of Republicans indicating they were opposed to Damore’s dismissal.33

Scientific Responses

Shortly after Damore was fired, scholars responded vigorously, many with lengthy, impassioned
arguments. Gina Rippon, the chair of cognitive brain imaging at Aston University, stated that something
biological could be overcome with practise and that the biological gender differences were “so tiny that
there’s no way that they can explain the kind of gender gap that’s apparent at Google.”34 Janet Hyde, a
psychology professor at the University of Wisconsin, concluded that “there’s every reason to think these
gender differences in interests are caused by socialisation factors.” Rosalind Barnett, senior scientist at the
Women’s Studies Research Center at Brandeis University, and Caryl Rivers, journalism professor at
Boston University, cited several scientists in their conclusion that there was little biological evidence for
sex differences, and that the “anxiety gap” existed not because of biology, but because competent women
were seen as bitchy, judged more harshly, and given less credit.35 Suzanne Sadedin, an evolutionary
biologist at Monash University, called Damore’s memo “despicable trash,” criticizing it for being
intellectually dishonest about its attacks on female inferiority, misrepresenting research on sex
differences, and failing to provide evidence of influences on performance in tech.36

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Cordelia Fine, a psychology professor at the University of Melbourne, thought that the memo “made
many dubious assumptions and ignored vast swaths of research that show pervasive discrimination
against women.” Nonetheless, she felt sorry for Damore because his points were “very familiar to me as
part of my day-to-day research, and are not seen as especially controversial.”37 Similarly, some scholars
focused on the validity of the research on gender differences without addressing the effect that science has
on perpetuating stereotypes about careers suitable for women. Lee Jussim, professor of social psychology
at Rutgers University, said that the memo got “nearly all of the science and its implications exactly right”
and was “certainly not a rant. And it stands in sharp contrast to most of the comments [criticisms], which
are little more than snarky modern slurs.” Geoffrey Miller, professor of evolutionary psychology at the
University of New Mexico, stated that “almost all of the Google memo’s empirical claims are
scientifically accurate. Moreover, they are stated quite carefully and dispassionately.”38 Debra Soh, a
sexual neuroscientist, called the memo “fair and factually accurate,” arguing that there were “sex
differences in the brain that lead to differences in our interests and behaviour.” Agreeing with Damore,
Soh noted that “gendered interests are predicted by exposure to prenatal testosterone—higher levels are
associated with a preference for mechanically interesting things and occupations in adulthood.”39

Responses from scholars cited by Damore in the memo were mixed. Richard Lippa, psychology professor at
California State University, called Damore’s summary of psychological differences “reasonably accurate,”
and Michael Wiederman, psychology professor at the University of South Carolina, believed that Damore
made “reasoned arguments” about why men could be more keen than women to climb the corporate ladder.
Catherine Hakim, sociologist at the think tank Civitas, believed that it was “nonsense” to link career
outcomes to psychological gender differences. Jüri Allik, professor of experimental psychology at the
University of Tartu, said that Damore’s extrapolations of personality research to career outcomes were
“risky” and that gender differences in his research were “very, very small.”40 David Schmitt, psychology
professor at Bradley University and founding director of the International Sexuality Description Project,
affirmed Damore’s conclusions drawing from cross-cultural data on personality differences; however, he
was hesitant to link personality directly to occupational differences between sexes. Schmitt did emphasize
that occupational differences were quite large and that nations that treated women more equally saw larger,
not smaller, differences in personality traits and occupational preferences.41


Diversity at Google

Google had grown to more than 75,000 employees by 2017.42 Women made up 30.8 per cent of Google’s
overall workforce in 2017; only 2.5 per cent of the company’s employees were black and only 3.6 per cent
were Hispanic or Latinx. Though the percentage of women in Google’s workforce had changed little since
2014 (when it was 30.6 per cent), the percentage of women in leadership and tech roles improved between
2014 and 2017, going from 20.8 to 24.5 per cent in leadership and from 16.6 to 20.2 per cent in tech,
compared with 48.1 to 48.4 per cent in non-tech roles (e.g., HR, marketing, and accounting). Attrition
among women was lower than for men, but gains in female representation were being made mainly among
white and Asian women.43 These figures compared unflatteringly to figures from the tech industry and the
private sector as a whole; female representation was 36 per cent in tech and 48 per cent in the private
workforce overall. Black employees represented 7.4 per cent of tech staff and 14.4 per cent of the overall
workforce, and Hispanic and Latinx employees represented 8.0 per cent and 13.9 per cent, respectively.44

In view of the relatively flat trends in the overall workforce, it was unclear where Google could make
improvements, whether by addressing internal biases or processes, or by working further upstream at the
sources of female candidates. Such trends did not seem to accord with the substantial sum of

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US$265 million it had spent on diversity programs over 2014 and 2015. The company eventually stopped
divulging its spending figures.45

In the wake of Damore’s memo, female employees became vocal about the nature of their experiences.
Wojcicki, one of Google’s first employees, shared her experiences in Fortune, which had named her the
16th most powerful woman in 2016:46

I’ve had my abilities and commitment to my job questioned. I’ve been left out of key industry events
and social gatherings. I’ve had meetings with external leaders where they primarily addressed the
more junior male colleagues. I’ve had my comments frequently interrupted and my ideas ignored until
they were rephrased by men. No matter how often this all happened, it still hurt.47

Another woman expressed hurt and frustration over years of getting caught up in internal discussion
threads “where men were louder than women on gender-bias and discrimination issues.” She attributed
the problem with “discrimination, harassment, and mental violence” to hiring for a certain male
stereotype that was not compatible with a hospitable environment for women.48

As a federal contractor required to conform to equal opportunity requirements, Google had been involved in
a lawsuit brought by the US Department of Labor that alleged that Google was underpaying women. The
day Damore was fired, a representative of the Department of Labor testified in court about the ongoing
investigation into Google. The department had found “systemic compensation disparities against women
pretty much across the entire workforce” at Google and “compelling evidence of very significant
discrimination against women in the most common positions at Google headquarters.” Within a month,
Google was served with a class-action lawsuit launched by three underpaid women who said that they were
placed at lower job levels and denied promotions and moves that could have advanced their careers.49

Inclusion at Google

The firm’s motto, “Don’t be evil,” encapsulated the high ideals Google put forth to make the world a
better place and to be unbiased and objective it how it handled search results.50 In the years before
Brown’s arrival, Google had already embarked on ambitious diversity programming. As early as 2014,
Nancy Lee, vice-president of people operations, wanted to fulfill Google’s original “don’t be evil”
mandate by initiating the full disclosure of its diversity figures, numbers that “weren’t great” but put
Google “on the hook. There’s no turning back.”51 A spokesperson for Google emphasized that the
company was “very committed to an open internal culture” of which “transparency [was] a huge part.”
The company was known to operate a wide range of platforms for open expression based on promotion of
the idea of “psychological safety,” in which employees were encouraged to share ideas without being
judged or embarrassed.52

Google applied considerable measures to improve hiring and promotion processes focused on women and
people of colour. These measures included implementing unconscious bias training, checking performance
review processes, and encouraging greater self-nomination.53 To address the challenge of an extremely low
representation of black Googlers, the company created an engineering residency for black computer science
majors and embedded engineers at historically black colleges. It also worked to foster an inclusive culture
by making sure its corporate events, town halls, and resource groups (e.g., Women@Google and Google
Women in Engineering) were welcoming and supportive.54 Google’s community-based programs included
partnerships with figures from Hollywood that aimed to inspire girls to pursue computer science and
programs introducing coding to high school students from diverse communities.55

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In an interview he gave after he was fired, Damore elaborated on his negative experiences with numerous
diversity events, including a weekly company-wide meeting (TGIF), mandatory unconscious bias
training, calls to hold individual managers accountable for their team’s diversity, and a weekly e-mail
allowing 20,000 employees to submit examples of micro-aggressions, some of which could implicitly
identify the perpetrators.56 In the lead-up to the Damore memo, some employees had taken measures into
their own hands, openly creating blacklists of those labelled “anti-diversity.” The threat of being reported
to human resources did not deter these list-keepers; rather, they used the reactionary comments to identify
others to add to their lists.57 It was not apparent from reports how prevalent this behaviour was or how
severely it affected the targeted co-workers.

Analysts highlighted the irony that, despite Google’s moral mission, the extreme views of controversial
far-right figures were bolstered by the followings they gained on Google-owned YouTube. The video
platform was accused of creating “filter bubbles” that drew users deeper into extreme content, capturing
the attention of disenfranchised groups.58 YouTube actively limited hate, violent extremist, supremacist,
or religious content that did not meet YouTube’s increasingly tough standards.59 With national politics
getting more divisive, analysts voiced their concerns that the company, having a reputation for liberal
views, could use its vast power over online searches to contain conservative thought.60

Sexism in Tech

In recent years, Silicon Valley and the tech sector had been known to have serious problems with sexual
diversity, discrimination, and harassment—issues that became widely known due to publicized cases at
other tech giants such as Uber Technologies Inc. and Twitter Inc..61 Women experienced being propositioned
for sex, dismissed, and disrespected and they had to fend off gropes and recover from interruptions by men
in meetings. Explanations for this behaviour attributed it to the origins of Silicon Valley in the “male realm”
of hardware, brotherhoods of young men coming out of college, the perception that “genius” was held only
by men, and the persistent sexist view that women achieved less and were fair game for objectification.62

High-ranking executives were not immune to the problem. Former Tinder executive Whitney Wolfe was
called a “whore” and “slut” by the firm’s marketing chief and unjustly denied the title of co-founder.63

Donna Harris, a venture capitalist who had started out as a systems engineer, remarked that her path to
success was “littered with rampant sexism, mansplaining, unconscious bias and some downright ugly
discrimination.”64 A coalition of seven women spearheaded a survey of 210 female peers working in
Silicon Valley, 25 per cent of whom were responding as top-ranking officers.65 A significant proportion
of these women experienced exclusion, disrespect, and mistreatment in their workplaces (see Exhibit 4).


In both the United States and Canada, universal rights to freedom of speech generally did not apply in the
workplace. Employers had a right to limit the types of speech that employees engaged in at work. Such
limitations extended outside the workplace if the employees’ conduct disrupted the legitimate business of
the employer.66 In California, employers could “fire workers at any time for any reason as long as it’s not
an illegal reason.”67 Illegal grounds for firing were covered under the National Labor Relations Act and
Title VII of the Civil Rights Act.68

Damore filed a complaint to the National Labor Relations Board the same day he was fired.69 The unfair
labour practice identified in the complaint referred to section 8(a)(1) of the National Labor Relations Act,
which stated that “It shall be an unfair labor practice for an employer to interfere with, restrain, or coerce

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employees in the exercise of the rights guaranteed in section 7.” The section 7 rights under the Act
protected employees who engaged in “concerted activities” to improve their pay and working conditions
or fix employment-related problems, even if the employees were not in a union.70

Cases governed by the Civil Rights Act were administered by the Equal Employment Opportunity (EEO)
Commission. Title VII made it illegal “to discriminate against someone on the basis of race, color,
religion, national origin, or sex.”71 Title VII also prohibited employers from “punishing job applicants or
employees for asserting their rights to be free from employment discrimination including harassment. . . .
Other acts to oppose discrimination [were also] protected as long as the employee was acting on a
reasonable belief that something in the workplace may violate EEO laws.”72

Google’s decision to fire Damore left observers wondering what precise issue resulted in a code-of-conduct
violation (see Exhibit 5).73 Neither party commented on any private employer–employee discussions that may
have influenced Google’s decision. Damore described the lead-up to his dismissal this way:

There is a dominant ideology at Google, and anyone who dissents against that is either shamed or
ostracized. And when it became apparent that I wasn’t backing down to the shame, they had to fire
me. . . . And it [the memo] was actually pointing out several practices at Google that went against
the code of conduct. So there are many practices that harass conservatives that have illegal bias
against certain groups. And I was simply pointing them out. And much of this is whistleblower stuff
where they really should not have fired me for pointing out illegal practices at Google.74


Riding high on the experience of success and harmony at Intel, Brown hoped that she could continue
making an impact as diversity officer of one of the most influential companies in the world. She was now
part of a corporate environment that seemed progressive on the surface but was permeated by strong
political views and simmering discomfort over the diversity program. With the controversy over the Damore
memo at the two-week mark, the company had taken a hard line on Damore and moved on. Multiple people
had written lengthy opinions about diversity and inclusion—staff, the press, academics—but Brown’s
communication had so far consisted of one short letter. With more than half of Google’s employees against
firing Damore, what steps should Brown take next to restore trust and promote candour?

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I’m Danielle, Google’s brand new VP of Diversity, Integrity & Governance. I started just a couple of weeks
ago, and I had hoped to take another week or so to get the lay of the land before introducing myself to you
all. But given the heated debate we’ve seen over the past few days, I feel compelled to say a few words.

Many of you have read an internal document shared by someone in our engineering organization,
expressing views on the natural abilities and characteristics of different genders, as well as whether one
can speak freely of these things at Google. And like many of you, I found that it [the memo] advanced
incorrect assumptions about gender. I’m not going to link to it here as it’s not a viewpoint that I or this
company endorses, promotes or encourages.

Diversity and inclusion are a fundamental part of our values and the culture we continue to cultivate. We are
unequivocal in our belief that diversity and inclusion are critical to our success as a company, and we’ll
continue to stand for that and be committed to it for the long haul. As Ari Balogh said in his internal G+ post,
“Building an open, inclusive environment is core to who we are, and the right thing to do. ’Nuff said.”

Google has taken a strong stand on this issue, by releasing its demographic data and creating a company-
wide OKR on diversity and inclusion. Strong stands elicit strong reactions. Changing a culture is hard, and
it’s often uncomfortable. But I firmly believe Google is doing the right thing, and that’s why I took this job.

Part of building an open, inclusive environment means fostering a culture in which those with alternative
views, including different political views, feel safe sharing their opinions. But that discourse needs to work
alongside the principles of equal employment found in our Code of Conduct, policies, and anti-
discrimination laws.

I’ve been in the industry for a long time, and I can tell you that I’ve never worked at a company that has
so many platforms for employees to express themselves—TGIF, Memegen, internal G+, thousands of
discussion groups. I know this conversation doesn’t end with my email today. I look forward to continuing
to hear your thoughts as I settle in and meet with Googlers across the company.



Note: OKR = objectives and key results.
Source: Sarah Emerson and Louise Matsakis, “Google on Anti-Diversity Manifesto: Employees Must ‘Feel Safe Sharing
Their Opinions,’” Motherboard, August 5, 2017, accessed January 31, 2018,

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Jan 2022 to Jul 2022.



Page 11 9B18C046

This has been a very difficult time. I wanted to provide an update on the memo that was circulated over
this past week.

First, let me say that we strongly support the right of Googlers to express themselves, and much of what
was in that memo is fair to debate, regardless of whether a vast majority of Googlers disagree with it.
However, portions of the memo violate our Code of Conduct and cross the line by advancing harmful
gender stereotypes in our workplace. Our job is to build great products for users that make a difference in
their lives. To suggest a group of our colleagues have traits that make them less biologically suited to that
work is offensive and not OK. It is contrary to our basic values and our Code of Conduct, which expects
“each Googler to do their utmost to create a workplace culture that is free of harassment, intimidation,
bias and unlawful discrimination.”

The memo has clearly impacted our co-workers, some of whom are hurting and feel judged based on
their gender. Our co-workers shouldn’t have to worry that each time they open their mouths to speak in a
meeting, they have to prove that they are not like the memo states, being “agreeable” rather than
“assertive,” showing a “lower stress tolerance,” or being “neurotic.”

At the same time, there are co-workers who are questioning whether they can safely express their views in
the workplace (especially those with a minority viewpoint). They too feel under threat, and that is also not
OK. People must feel free to express dissent. So to be clear again, many points raised in the memo—such
as the portions criticizing Google’s trainings, questioning the role of ideology in the workplace, and debating
whether programs for women and underserved groups are sufficiently open to all—are important topics. The
author had a right to express their views on those topics—we encourage an environment in which people
can do this and it remains our policy to not take action against anyone for prompting these discussions.

The past few days have been very difficult for many at the company, and we need to find a way to debate
issues on which we might disagree—while doing so in line with our Code of Conduct. I’d encourage each
of you to make an effort over the coming days to reach out to those who might have different perspectives
from your own. I will be doing the same.

I have been on work related travel in Africa and Europe the past couple of weeks and had just started my
family vacation here this week. I have decided to return tomorrow as clearly there’s a lot more to discuss
as a group—including how we create a more inclusive environment for all.

Source: Sundar Pichai, “Note to Employees from CEO Sundar Pichai,” The Keyword (blog), Google, August 8, 2017,
accessed January 30, 2018, www.blog.google/topics/diversity/note-employees-ceo-sundar-pichai.

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This document is authorized for use only by Ricardo Godoy in Spring 2022-Stark Case Studies Management & Leadership-Section 002 taught by MARTHA STARK, New York University from
Jan 2022 to Jul 2022.



Page 12 9B18C046

Question: “Was Google right in firing manifesto author, Damore?”

Company Yes No
Uber Technologies Inc. 36% 64%

Yahoo! 40%


Airbnb, Inc. 42% 58%

Microsoft Corporation 43% 57%

Google LLC (441 participants) 44% 56%

Facebook, Inc. 44% 56%

Amazon.com, Inc. 46% 54%

LinkedIn Corporation 53% 47%

Lyft 65% 35%

Source: Created by the case authors using data from Blind, an anonymous work talk app, provided in Julie Bort, “Over Half
of Google Employees Polled Say the Web Giant Shouldn’t Have Fired the Engineer Behind the Controversial Memo,”
Business Insider, August 9, 2017, accessed February 9, 2018, www.businessinsider.com/many-google-employees-dont-


Question Response
Have been told that they are too aggressive 84%

Asked to do lower-level tasks that male colleagues are not asked to do 47%

Felt excluded from social/networking opportunities because of gender 66%

Have felt they have not had the same opportunities as their male counterparts 59%

Witnessed sexist behaviour at company offsites and/or industry conferences 90%
Have experienced clients/colleagues address questions to male peers that should have
been addressed to them


Demeaning comments from male colleagues 87%

Were asked about family life, marital status, and children in interviews 75%

Feel the need to speak less about their family to be taken more seriously 40%
Reported unwanted sexual advances

Of those reporting, had received advances from a superior

Of those reporting sexual harassment, were dissatisfied with the course of action:
Of those harassed:

Did nothing because they thought it would negatively impact their career
Did not report, because they wanted to forget
Signed a non-disparagement agreement



Source: Trae Vassallo, Ellen Levy, Michele Madansky, Hillary Mickell, Bennett Porter, Monica Leas, and Julie Oberweis,
Elephant in the Valley, accessed February 12, 2018, www.elephantinthevalley.com.

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Jan 2022 to Jul 2022.



Page 13 9B18C046



“Don’t be evil.” Googlers generally apply those words to how we serve our users. But “Don’t be evil” is much
more than that. Yes, it’s about providing our users unbiased access to information, focusing on their needs
and giving them the best products and services that we can. But it’s also about doing the right thing more
generally—following the law, acting honorably, and treating co-workers with courtesy and respect.

The Google Code of Conduct is one of the ways we put “Don’t be evil” into practice. It’s built around the
recognition that everything we do in connection with our work at Google will be, and should be, measured
against the highest possible standards of ethical business conduct. We set the bar that high for practical
as well as aspirational reasons: Our commitment to the highest standards helps us hire great people,
build great products, and attract loyal users. Trust and mutual respect among employees and users are
the foundation of our success, and they are something we need to earn every day.

So please do read the Code, and follow both its spirit and letter, always bearing in mind that each of us
has a personal responsibility to incorporate, and to encourage other Googlers to incorporate, the
principles of the Code into our work. And if you have a question or ever think that one of your fellow
Googlers or the company as a whole may be falling short of our commitment, don’t be silent. We want—
and need—to hear from you.

II. Support Each Other

2. Harassment, Discrimination, and Bullying

Google prohibits discrimination, harassment and bullying in any form—verbal, physical, or visual, as
discussed more fully in our Policy Against Discrimination, Harassment and Retaliation. If you believe
you’ve been bullied or harassed by anyone at Google, or by a Google partner or vendor, we strongly
encourage you to immediately report the incident to your supervisor, Human Resources or both. Similarly,
supervisors and managers who learn of any such incident should immediately report it to Human
Resources. HR will promptly and thoroughly investigate any complaints and take appropriate action.

Note: Excerpted from the Code of Conduct in force in July 2017. Google has since revised its Code of Conduct.
Source: “Google Code of Conduct,” Alphabet Investor Relations [archive], accessed April 21, 2018,

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Jan 2022 to Jul 2022.


Page 14 9B18C046


1 This case was written on the basis of accounts published primarily in mainstream journalistic media without efforts to
confirm sources or proportionally represent views found in non-mainstream media (e.g., blogs, videos, and comments). Most
sources were published within two weeks of the leak of the memo. Consequently, the perspectives presented in this case
are not necessarily those of the author, Google, or any of its existing or former employees, and do not reflect changes in
views or events after the period of research.
2 Kara Swisher, “Google Has Hired a Diversity VP—Just as It Struggles with a Sexist Memo from an Employee,” Recode, August 5,
2017, accessed February 8, 2018, www.recode.net/2017/8/5/16102476/google-diversity-vp-employee-memo.
3 “Danielle Mastrangel Brown: Experience,” LinkedIn, accessed May 31, 2018, www.linkedin.com/in/danielle-mastrangel-
4 “How Did I Get Here? Danielle Brown,” Bloomberg, accessed May 31, 2018, www.bloomberg.com/features/2017-how-did-i-
get-here/danielle-brown.html; “GHC 16—Brian Krzanich and Danielle Brown of Intel Discuss Their Bold Goal to Increase
Diversity,” YouTube video, 1:01:29, posted by “AnitaB_org,” June 29, 2017, accessed May 31, 2018,
5 Sarah Green Carmichael, “Making Intel More Diverse,” Harvard Business Review, March 10, 2017; Mark Chatham, “What
Is the Corporate Culture Like at Intel? How Is the Culture Different Than Other Companies?,” Quora (blog), August 5, 2017,
accessed May 31, 2018, www.quora.com/What-is-the-corporate-culture-like-at-Intel-How-is-the-culture-different-than-other-
6 Daisuke Wakabayashi, “Contentious Memo Strikes Nerve Inside Google and Out,” New York Times, August 8, 2017,
accessed October 10, 2018, www.nytimes.com/2017/08/08/technology/google-engineer-fired-gender-memo.html; Paul
Lewis, “‘I See Things Differently’: James Damore on His Autism and the Google Memo,” Guardian, November 17, 2017,
accessed January 29, 2018, www.theguardian.com/technology/2017/nov/16/james-damore-google-memo-interview-autism-
7 James Damore, “Google’s Ideological Echo Chamber: How Bias Clouds Our Thinking about Diversity and Inclusion,” July
2017, accessed January 29, 2018, https://web.archive.org/web/20170809220001/https://diversitymemo-static.s3-us-west-
2.amazonaws.com/Googles-Ideological-Echo-Chamber ; Louise Matsakis, Jason Koebler, and Sarah Emerson, “Here Are
the Citations for the Anti-Diversity Manifesto Circulating at Google,” Motherboard, August 7, 2017, accessed May 31, 2018,
8 Louise Matsakis, “Google Employee’s Anti-Diversity Manifesto Goes ‘Internally Viral,’” Motherboard, August 5, 2017,
accessed January 31, 2018, https://motherboard.vice.com/en_us/article/kzbm4a/employees-anti-diversity-manifesto-goes-
9 Shona Ghosh, “The Fired Google Engineer Wrote his Memo after He Went to a ‘Shaming,’ ‘Secretive’ Diversity Program,”
Business Insider, August 9, 2017, accessed January 30, 2018, www.businessinsider.com/james-damore-wrote-his-memo-
10 Seth Fiegerman and Sara Ashley O’Brien, “Google Wrestles with Aftermath from Controversial Memo,” CNN Business,
August 11, 2017, accessed February 1, 2018, http://money.cnn.com/2017/08/11/technology/business/google-memo-
aftermath/index.html; Jack, “Peaceful March on Google Postponed Due to Alt Left Terrorist Threats,” #MarchOnGoogle,
August 16, 2017, accessed February 15, 2018, www.marchongoogle.com/peaceful-march-on-google-postponed-due-to-alt-
left-terrorists; Lewis, op. cit.
11 James Damore, “Why I Was Fired by Google,” Wall Street Journal, August 11, 2017, accessed January 31, 2018,
www.wsj.com/articles/why-i-was-fired-by-google-1502481290; Steve Kovach and Chris Snyder, “Fired Google Engineer
Says his Memo Actually Empowered Women,” Business Insider, August 17, 2017, accessed February 1, 2018,
http://uk.businessinsider.com/james-damore-interview-video-2017-8; Shona Ghosh, “Fired Google Engineer James Damore
Spent Hours Answering Questions on Reddit,” Business Insider, August 14, 2017, accessed February 1, 2018,
12 Damore, “Google’s Ideological Echo Chamber,” op. cit.
13 Ibid.
14 Ibid.
15 Ibid.
16 Kovach and Snyder, op. cit.; Alexei Oreskovic, “A Senior Engineer at Google Wrote a Controversial Diversity Manifesto
and Employees Are Furious,” Business Insider, August 5, 2017, accessed February 13, 2018,
17 Sarah Emerson and Louise Matsakis, “Google on Anti-Diversity Manifesto: Employees Must ‘Feel Safe Sharing Their
Opinions’,” Motherboard, August 5, 2017, accessed January 31, 2018,
18 Sundar Pichai, “Note to Employees from CEO Sundar Pichai,” The Keyword (blog), Google, August 8, 2017, accessed
January 30, 2018, www.blog.google/topics/diversity/note-employees-ceo-sundar-pichai.
19 Damore, “Why I Was Fired by Google,” op. cit.; Oreskovic, op. cit.; Lewis, op. cit.
20 Lewis, op. cit.; “Attacking Dissent at Google,” Vox Popoli, August 6, 2017, accessed February 17, 2018,

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Page 15 9B18C046

21 Ben Johnson and Jana Kasperkevic, “The Sexist Memo Could Cost Google Employees—Some Say They’ve Already
Started Interviewing Elsewhere,” Business Insider, August 9, 2017, accessed August 9, 2018,
22 Steve Kovach, “Female Employee on the Google Memo: I Don’t Know How We Could Feel Anything but Attacked by
That,” Business Insider, August 13, 2017, accessed February 7, 2018, www.businessinsider.com/female-google-employee-
23 Susan Wojcicki, “Read YouTube CEO Susan Wojcicki’s Response to the Controversial Google Anti-Diversity Memo,”
Fortune, August 9, 2017, accessed February 7, 2018, http://fortune.com/2017/08/09/google-diversity-memo-wojcicki.
LGBTQ = lesbian, gay, bisexual, transgendered, and queer or questioning.
24 Wakabayashi, op. cit.
25 Sarah Emerson, Louise Matsakis, and Jason Koebler, “Internal Reactions to Google Employee’s Manifesto Show Anti-
Diversity Views Have Support,” Motherboard, August 5, 2017, accessed February 17, 2018,
26 Kovach and Snyder, op. cit.
27 “Over Half of Google Employees Polled Say the Web Giant Shouldn’t Have Fired the Engineer Behind the Controversial
Memo,” Business Insider, August 9, 2017, accessed February 9, 2018, www.businessinsider.com/many-google-employees-
28 Clare O’Connor, “Google Fires Anti-Diversity Memo Writer, Drawing Ire in Right-Wing Circles,” Forbes, August 8, 2017,
accessed February 7, 2018, www.forbes.com/sites/clareoconnor/2017/08/08/google-fires-anti-diversity-memo-writer-
29 Angela Saini, “Silicon Valley’s Weapon of Choice against Women: Shoddy Science,” Guardian, August 7, 2017, accessed
February 8, 2018, www.theguardian.com/commentisfree/2017/aug/07/silicon-valley-weapon-choice-women-google-
30 Cynthia Lee, “James Damore Has Sued Google. His Infamous Memo on Women in Tech Is Still Nonsense,” Vox, January
8, 2018, accessed February 7, 2018, www.vox.com/the-big-idea/2017/8/11/16130452/google-memo-women-tech-biology-
31 Margaret Wente, “Nerdy Guy Writes Memo, World Has Nervous Breakdown,” Globe and Mail, August 11, 2017, accessed
February 8, 2018, www.theglobeandmail.com/opinion/nerdy-guy-writes-memo-world-has-nervous-
32 Megan McArdle, “Commentary: That Google Memo about Women in Tech Wasn’t Wrong,” Chicago Tribune, August 11,
2017, accessed February 8, 2018, www.chicagotribune.com/news/opinion/commentary/ct-google-memo-women-tech-
33 Jonathan Easley, “Poll: Google Was Wrong to Fire Engineer over Diversity Memo,” The Hill, August 28, 2017, accessed
February 9, 2018, http://thehill.com/policy/technology/348246-poll-google-was-wrong-to-fire-engineer-over-diversity-memo.
34 Nalina Eggert, “Was Google Wrong to Fire James Damore after Memo Controversy?,” BBC News, August 8, 2017,
accessed February 7, 2018, www.bbc.com/news/world-40865261.
35 Rosalind Barnett and Caryl Rivers, “We’ve Studied Gender and STEM for 25 Years. The Science Doesn’t Support the
Google Memo,” Recode, August 11, 2017, accessed February 8, 2018, www.recode.net/2017/8/11/16127992/google-
36 Suzanne Sadedin, “A Scientist’s Take on the Biological Claims from the Infamous Google Anti-Diversity Memo,” Forbes,
August 13, 2017, accessed February 7, 2018, www.forbes.com/sites/quora/2017/08/10/a-scientists-take-on-the-biological-
37 Lewis, op. cit.
38 Lee Jussim, David P. Schmitt, Geoffrey Miller, and Debra W. Soh, “The Google Memo: Four Scientists Respond,”
Quillette, August 7, 2017, accessed February 4, 2018, http://quillette.com/2017/08/07/google-memo-four-scientists-respond.
39 Debra Soh, “No, the Google Manifesto Isn’t Sexist or Anti-Diversity. It’s Science,” Globe and Mail, August 8, 2017,
accessed February 3, 2018, www.theglobeandmail.com/opinion/no-the-google-manifesto-isnt-sexist-or-anti-diversity-its-
40 Lewis, op. cit.
41 David P. Schmitt, “On that Google Memo about Sex Differences,” Psychology Today, August 7, 2017, accessed February
7, 2018, www.psychologytoday.com/blog/sexual-personalities/201708/google-memo-about-sex-differences.
42 Rani Molla, “Alphabet Has Nearly Doubled Its Headcount since 2013 to More Than 75,000,” Recode, July 24, 2017, accessed
July 12, 2018, www.recode.net/2017/7/24/16022210/alphabet-google-employment-employees-doubled-headcount.
43 Google, Google Diversity Annual Report 2018 (Mountain View, CA: Google, 2018), accessed July 12, 2018,
https://diversity.google/static/pdf/Google_Diversity_annual_report_2018 .
44 Grace Donnelly, “Google’s 2017 Diversity Report Shows Progress Hiring Women, Little Change for Minority Workers,”
Fortune, June 29, 2017, accessed July 12, 2018, http://fortune.com/2017/06/29/google-2017-diversity-report.
45 Beth Winegarner, “Google’s Hardest Moonshot: Debugging Its Race Problem,” Fast Company, February 2, 2017,
accessed July 12, 2018, www.fastcompany.com/3066914/google-and-tech-struggle-to-hack-bias-and-diversity.
46 Jena McGregor, “One of Google’s Highest-Ranking Women Has Answered that Controversial Memo with a Very Personal
Essay,” Washington Post, August 9, 2017, accessed February 18, 2018, www.washingtonpost.com/news/on-

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Poll: Google was wrong to fire engineer over diversity memo











Page 16 9B18C046

essay; “Most Powerful Women: 2016,” Fortune, accessed October 12, 2018, http://fortune.com/most-powerful-women/2016.
47 Wojcicki, op. cit.
48 Charlie Nash, “Revealed: Google’s Social Justice Warriors Create Wrongthink Blacklists,” Breitbart, August 7, 2017,
accessed February 17, 2018, www.breitbart.com/tech/2017/08/07/revealed-inside-googles-sjw-cabal-blacklists.
49 Seth Fiegerman, “Google Is in Court Fighting over How It Pays Women,” CNN Business, August 9, 2017, accessed February 1,
2018, http://money.cnn.com/2017/08/09/technology/business/google-labor-lawsuit; Sam Levin, “Google Accused of ‘Extreme’ Gender
Pay Discrimination by US Labor Department,” Guardian, April 7, 2017, accessed February 17, 2018,
www.theguardian.com/technology/2017/apr/07/google-pay-disparities-women-labor-department-lawsuit; Jessica Guynn, “Google Puts
Women in Lower Level, Lower Paying Jobs, New Lawsuit Says,” USA Today, September 14, 2017, accessed February 17, 2018,
50 Google Inc., Amendment No. 9 to Form S-1 Registration Statement under the Securities Act of 1933, Initial Public Offering
(Registration No. 333-114984), accessed February 16, 2018,
51 Liza Mundy, “Why Is Silicon Valley So Awful to Women?,” Atlantic, April 2017, accessed February 17, 2018,
52 Nick Statt, “A Google Employee Is Suing the Company for Being Too Confidential,” Verge, December 20, 2016, accessed February
13, 2018, www.theverge.com/2016/12/20/14033044/google-lawsuit-confidentiality-practices-spying-program; Lewis, op. cit.
53 Nancy Lee, “Focusing on Diversity,” The Keyword (blog), Google, June 30, 2016, accessed July 12, 2018,
54 Eileen Naughton, “Making Progress on Diversity and Inclusion,” The Keyword (blog), Google, June 29, 2017, accessed
July 12, 2018, www.blog.google/outreach-initiatives/diversity/making-progress-diversity-and-inclusion.
55 Nancy Lee, “Doing More on Diversity,” The Keyword (blog) Google, May 5, 2015, accessed July 12, 2018,
56 Cathy Young, “An Interview with James Damore,” Reason, August 14, 2017, accessed February 1, 2018,
57 Nash, op. cit.
58 Sam Levin, “James Damore, Google and the YouTube Radicalization of Angry White Men,” Guardian, August 13, 2017, accessed
February 1, 2018, www.theguardian.com/technology/2017/aug/13/james-damore-google-memo-youtube-white-men-radicalization.
59 YouTube, “An Update on Our Commitment to Fight Terror Content Online,” YouTube Official Blog, August 1, 2018,
accessed February 17, 2018, https://youtube.googleblog.com/2017/08/an-update-on-our-commitment-to-fight.html.
60 Erick Erickson, “Why Google’s Firing Terrifies Social Conservatives So Much,” Washington Post, August 7, 2017,
accessed February 8, 2018, www.washingtonpost.com/news/acts-of-faith/wp/2017/08/08/why-googles-firing-terrifies-social-
61 “Does Silicon Valley Have a Sexism Problem?,” BBC News, February 21, 2017, accessed February 12, 2018,
62 Mundy, op. cit.
63 “Does Silicon Valley Have a Sexism Problem?,” op. cit.
64 Donna Harris, “I’m a Successful Woman in Tech—And I Didn’t Complain to HR about the Sexual Harassment I’ve
Experienced,” Business Insider, August 11, 2017, accessed February 8, 2018, www.businessinsider.com/a-vc-tells-the-
65 Trae Vassallo, Ellen Levy, Michele Madansky, Hillary Mickell, Bennett Porter, Monica Leas, and Julie Oberweis, Elephant
in the Valley, accessed February 12, 2018, www.elephantinthevalley.com/.
66 Jim Edwards, “James Damore, the Google Employee Fired for His Controversial Manifesto, Is (Almost Certainly) Not a
Victim of a Free-Speech Violation,” Business Insider, August 8, 2017, accessed February 8, 2018,
67 Jena McGregor, “The Google Memo is a Reminder that We Generally Don’t Have Free Speech at Work,” Washington
Post, August 8, 2017, accessed January 30, 2018, www.washingtonpost.com/news/on-leadership/wp/2017/08/08/the-
68 National Labor Relations Act of 1935 (49 Stat. 449) 29 U.S.C. §151–169; Civil Rights Act of 1964 (Pub. L. 88–352, 78
Stat. 241, enacted July 2, 1964).
69 National Labor Relations Board, Google, Inc., A Subsidiary of Alphabet, Inc., Case 32-CA-203891 (2017), accessed
February 13, 2018, www.nlrb.gov/case/32-CA-203891.
70 “National Labor Relations Act,” National Labor Relations Board, accessed February 13, 2018, “Rights We Protect,”
National Labor Relations Board, accessed February 13, 2018, www.nlrb.gov/rights-we-protect.
71 “Laws Enforced by EEOC,” U.S. Equal Employment Opportunity Commission, accessed October 10, 2018,
72 “Facts About Retaliation,” U.S. Equal Employment Opportunity Commission, accessed February 15, 2018,
73 Conor Friedersdorf, “A Question for Google’s CEO,” Atlantic, August 11, 2017, accessed February 9, 2018,
74 Kovach and Snyder, op. cit.

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