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COMPLAINT FOR DAMAGES
Mr. Mateen and Mr. Rad subjected Ms. Wolfe to a barrage of horrendously sexist, racist, and otherwise inappropriate comments, emails and text messages, including describing one person as a “liberal lying desperate slut” and others as “middle age Muslim pigs” and referring, for example, to “fucking” the wife of a prominent blogger, and a text depicting IAC Chairman Barry Diller as a penis. Although it is tempting to describe the conduct of Tinder’s senior executives as “frat-like,” it was in fact much worse- representing the worst of the misogynist, alpha-male stereotype too often associated with technology startups. 3.
Although Ms. Wolfe repeatedly complained to CEO Rad, he ignored her complaints, dismissing her as “annoying” and “dramatic,” and threatened her job. Ms. Wolfe finally broke down the night that Mr. Mateen called her a “whore” at a company event, and she offered to resign in consideration for modest severance and the vesting of her stock. Mr. Rad snidely rejected the offer and fired her.
Plaintiff is a resident of the County of Los Angeles, State of California. During the entire period of time at issue in this lawsuit, Plaintiff resided in Los Angeles County, in the State of California. She worked for Defendants in Los Angeles County, California throughout her employment. 5.
Tinder is a corporation headquartered and doing business in the State of California County of Los Angeles. 6.
Match.com is a corporation doing business in the State of California County, with offices in West Hollywood, County of Los Angeles. 7.
IAC, Inc. is a corporation doing business in the State of California County of Los Angeles. Upon information and belief, IAC, Inc. is the majority owner of Tinder. 8.
Plaintiff is informed and believes, and thereon alleges, that each of the Defendants was, at all times herein mentioned, the agent, employee, partner and/or representative of one or more of the remaining Defendants and was acting within the course and scope of such relationship. Plaintiff is further informed and believes that each of the Defendants herein gave consent to, ratified and authorized the acts alleged herein to each of the remaining Defendants.