ROSEN + Saga, iP 9350 Wilshire Boulevard, Suite 250, Beverly Hills, CA 90212 14 15 16 7 18 19 20 2 22 23. 24 25 ROSEN + SABA, LLP RYAN D. SABA, ESQ. (State Bar No. 192370) 1s saba.com TYLER C. VANDERPOOL, ESQ. (State Bar No. 279175) ‘tvanderpool| aba.com iz 9350 Wilshire Boulevard, Suite 250 Beverly Hills, California 90212 Telephone: (310) 285-1727 Facsimile: (310) 285-1728 Attomeys for Plaintifis, MELANIE MCCRACKEN and JESSICA NEGRON, SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES—CENTRAL DISTRICT MELANIE MCCRACKEN, an individual, | Case No. atid JESSICA NEGRON, an individual, a Plainiiffs, COMPLAINT FOR DAMAGES v. 1. Violation of California Equal Pay Act (Cal. Lab. Code §1197.5(a)) RIOT GAMES, INC., a Delaware 2 Discrimination and Retaliation in : Violation of California Equal Pay Act corporation; and DOES 1 through 10 (Cal Lab Code Shion seg inclusive, 3. Discrimination in Violation of the Fair Employment & Housing Act (Cal. Defendants, Gov't. Code §12940(a)) 4, Harassment in Violation of the Fair Employment & Housing Act (Cal. Gov't, Code §12940()(1)) 5. Retaliation in Violation of the Fair Employment & Housing Act (Cal. Gov't, Code §12940(h)) 6. Failure to Prevent Discrimination, Harassment, and Retaliation in Violation of the Fair Employment & Housing Act (Cal. Gov't. Code §12940(k)) 7. Constructive Termination in Violation of California Law and Public Policy 8. Violations Of Unfair Competition Law Bus. & Prof. Code §17200, et seq.) 28 ‘COMPLAINTROSEN Sasa, LLP 9350 Wilshire Boulevard, Suite 250, Beverly Hits, CA 90212 TO THIS HONORABLE COURT AND ALL INTERESTED PARTIES: NOW COME Plaintiffs MELANIE MCCRACKEN and JESSICA NEGRON (collectively, “Plaintiffs”) who allege causes of action, individually and on behalf of a class of other similarly- situated current and former California employees, against Defendants RIOT GAMES, INC. (“Riot Games”), a Delaware corporation, and DOES | through 10, inclusive, (collectively, “Defendants”) as follows: NATURE OF ACTION 1. Plaintiffs Melanie McCracken and Jessica Negron are, respectively, a current and former employee of Riot Games. Like many of Riot Games’ female employees, Plaintiffs have been | 10 11 | denied equal pay and found their careers stifled because they are women. Moreover, Plaintiffs have 12 | also seen their working conditions negatively impacted because of the ongoing sexual harassment, 18 | misconduct, and bias which predominate the sexually-hostile working environment of Riot Games, 14 2. The term used to identify and instill the ideals of a Riot Games employee is “Rioter.” 15 | The primary tenet of being a “Rioter” is being a “core gamer.” While the term is ostensibly meant 416 | t0 promote the hiring and advancement of people who are video game fanatics, it has a more 17 | nefarious meaning to its female employees. Specifically, the term “core gamer” is an unwritten 18 | policy and practice of preferring men to women in the hiring, promotion, and compensation of its 19 | employees. It is also a conduit to forcing its female employees to endure the sexual harassment and 20 | misconduct that has plagued “gaming culture,” and to keep silent about these issues. In sum, being 24 | a “core gamer” equates to being a man, and the presumption is that women are not core gamers and 22 | therefore not true “Rioters.” 23 3. Recently, 1wo major news publications commenced a series of in-depth reports on 24 | the extensive sexual harassment and gender discrimination that has been cultivated at Riot Games 25 | by its leadership. However, even though the issues plaguing Riot Games have come to light in a 26 | public forum, Riot Games is simply sweeping these allegations under the rug with empty 27 | investigations and counseling, while protecting the bad actors from any repercussion. The prevalent 2 | misconduct cannot be ignored any longer, as Plaintiffs seek to ensure the complaints of all female 2 COMPLAINTROSEN} SABA, LLP 9350 Wishire Boulevard, Suite 250, Beverly Hills, CA 90212 10 " 12 B 14 18 16 7 18 19 20 a 22 23 24 25 26 ar 28 employees of Riot Games are taken seriously and acted upon. Accordingly, on behalf of themselves: and on behalf of a proposed class of similarly-situated current and former California employees of Riot Games, Plaintiff's bring this class action lawsuit to obtain monetary damages and cause social change for the misconduct perpetrated by Riot Games. 4. Specifically, Plaintiffs seek to stop Riot Games’ custom and practice of (@) paying women less than similarly-situated men; (b) assigning women to jobs that Riot Games does not ‘compensate as highly as those jobs populated by men, even when women are equally qualified for the more highly compensated jobs; (c) promoting similarly-situated and qualified men more frequently than women who are equally or more qualified for promotion; (4) assigning or demoting ‘women to lower paid positions than similatly-situated men, even when these women’s qualifications were equal to or greater than the men’s qualifications; and () creating, encouraging, and maintaining a work environment that exposes its female employees to discrimination, harassment, and retaliation ‘on the basis of their gender or sex. THE PARTIES 5. Plaintiff’ Melanie McCracken is an adult female resident of the County of Los Angeles, State of California, and has been employed by Riot Games from approximately October 2013 through the present. 6. Plaintiff Jessica Negron is an adult female resident of the State of Connecticut and was employed by Riot Games from approximately April 2015 through April 2017, 7. Defendant Riot Games is a corporation duly organized and existing under the laws of the State of Delaware, with its principal place of business located at 12333 West Olympic Boulevard, Los Angeles, California 90064. Riot Games was founded in 2006 and is a video game developer, best known for creating and selling “League of Legends,” a multiplayer online battle- arena game and the company’s banner product. Riot Games operates 24 offices around the world and employs approximately 2,500 staff members of which 80% of whom are male, At all relevant times, Riot Games was and is doing business in the City of Los Angeles, County of Los Angeles, State of California, 3 COMPLAINT