Brown v. Alphasense, Inc.

CourtDistrict Court, District of Columbia
DecidedJuly 1, 2026
DocketCivil Action No. 2025-4507
StatusPublished

This text of Brown v. Alphasense, Inc. (Brown v. Alphasense, Inc.) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Alphasense, Inc., (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

CAMERON ANGEL BROWN,

Plaintiff,

v. Case No. 1:25-cv-4507 (TNM)

ALPHASENSE, INC.,

Defendant.

MEMORANDUM OPINION

Cameron Brown is a lawyer with a shiny resume and a frustrating tale. Last year, he

hoped to leave his elite law firm to work for a tech startup called AlphaSense. The job, however,

did not pan out. According to Brown, AlphaSense refused to hire him because he would not

violate ethical and confidentiality obligations that he owed his law firm. He sued AlphaSense in

the Superior Court of the District of Columbia alleging that the company retaliated against and

penalized him for engaging in activity protected by the District of Columbia Human Rights Act

(“DCHRA”). AlphaSense removed the case here and now moves to dismiss. Brown opposes

dismissal and seeks remand. Because the Court has jurisdiction over the case, it will deny

Brown’s remand request. And the Court will dismiss the case because Brown’s own exhibits

contradict his story that he engaged in protected activity.

I.

Cameron Brown is a Stanford-educated lawyer who worked as a litigation associate at

Paul Hastings LLP until recently. Compl. ¶ 11, ECF No. 1-1; see Pl.’s Ex. A at 2, ECF No. 1-2

(Brown’s resume). Last spring, he decided he was ready for a change and applied for positions at several tech companies. See Compl. ¶ 12; Pl.’s Ex. B at 3, ECF No. 1-3. AlphaSense was one

of those companies. Compl. ¶ 12.

In late April 2025, after completing much of AlphaSense’s interview process, Brown

learned that the company would not offer him the job. Pl.’s Ex. B at 2; see Compl. ¶ 17. At

Brown’s request for “candid feedback” on his candidacy, AlphaSense’s Vice President of

Legal—Herbert Wang—connected with him. Pl.’s Ex. B at 2. Over the next week, Wang and

Brown emailed about Wang’s attempts to confirm Brown’s standing with Paul Hastings. See id.

at 2–4. In the end, Paul Hastings would not talk to Wang about Brown’s performance and

AlphaSense moved on to other candidates. See id. at 4.

A few months later, Brown sued AlphaSense in Superior Court. See generally Compl.

He claims that AlphaSense violated the DCHRA in three ways. Id. ¶¶ 30–44. Each claim turns

on Brown’s allegation that AlphaSense violated the Act by “condition[ing] his continued

candidacy on inducing” Brown to get Paul Hastings to “disclose confidential information.” Id.

¶ 4. When Brown “declined to breach confidentiality obligations owed to his former employer,”

he says, AlphaSense ended the job talks. Id.

In late December, AlphaSense removed the case here. Notice of Removal, ECF No. 1.

Its motion to dismiss followed. Mot. to Dismiss, ECF No. 5. Brown opposes dismissal and also

asks the Court to remand the case. Opp’n to Mot. to Dismiss (“Pl.’s Opp’n”), ECF No. 14; Mot.

to Remand, ECF No. 8. Both the remand motion and the dismissal motion are ripe. The Court

takes each in turn.

II.

First up is Brown’s remand request. Brown argues that the Court lacks jurisdiction

because AlphaSense did not immediately file a removal notice in Superior Court. See Mot. to

2 Remand at 2–3. That is wrong. Remand is inappropriate because the Court has jurisdiction and

AlphaSense has rectified the defect.

AlphaSense was entitled to remove this case to federal court because the diversity

jurisdiction statute gives this Court “original jurisdiction” over the matter. 28 U.S.C. § 1441(a)

(permitting removal of “any civil action brought in a State court of which the district courts of

the United States have original jurisdiction”); see id. § 1451(1) (defining “State court” for

removal purposes to include the Superior Court of the District of Columbia). The diversity

statute grants district courts “original jurisdiction of all civil actions where the matter in

controversy exceeds the sum or value of $75,000,” and, as relevant here, “is between . . . citizens

of different States.” Id. § 1332(a). The parties are diverse. See Compl. ¶ 9 (Brown is a D.C.

citizen); id. ¶ 10 (AlphaSense “is a Delaware corporation headquartered in New York”). And the

amount-in-controversy requirement is also met. Although Brown does not allege a specific

damage amount, AlphaSense points out that Brown’s requested damages for the lost job would

“plainly” exceed “$75,000.00.” Notice of Removal ¶ 7. Brown does not object. So the Court

accepts that the amount-in-controversy requirement is met. See Dart Cherokee Basin Operating

Co., LLC v. Owens, 574 U.S. 81, 87 (2014) (“[W]hen a defendant seeks federal-court

adjudication, the defendant’s amount-in-controversy allegation should be accepted when not

contested by the plaintiff or questioned by the court.”). So jurisdiction exists.

Brown maintains, however, that AlphaSense’s procedural error deprives this Court of

jurisdiction. See Mot. to Remand at 2–4. Two removal procedures are relevant to that argument.

First, the defendant must file the “notice of removal” in federal court “within 30 days after”

receiving the initial pleading. 28 U.S.C. § 1446(b)(1). AlphaSense did so. See Notice of

Removal at 1–2. Second, “[p]romptly after the filing of such notice of removal of a civil action

3 the defendant” must “file a copy of the notice with the clerk of such State court.” 28 U.S.C.

§ 1446(d). Brown concentrates on this second requirement. When Brown moved to remand,

AlphaSense had not yet provided that notice. See Mot. to Remand at 3; Superior Court Docket at

3, ECF No. 8-1. AlphaSense rectified the issue two days after it received Brown’s motion.

Burns Decl. ¶¶ 4–5, ECF No. 12-3. Even so, Brown says remand is necessary. See Pl.’s Reply,

ECF No. 15. He is wrong.

First, Brown incorrectly describes the prompt notice requirement as jurisdictional. See,

e.g., Mot. to Remand at 2, 6. Failure to file a copy of the removal notice with the state court is a

procedural defect, not a jurisdictional one. Koerner v. Aetna U.S. Healthcare, Inc., 92 F. App’x

394, 396 (9th Cir. 2003); see Harris v. Dep’t of Transp., 122 F.4th 418, 425 (D.C. Cir. 2024)

(holding that “the timeliness of removal under section 1446 is a procedural claims-processing

rule and is not jurisdictional”). So AlphaSense’s error does not affect jurisdiction.

Second, AlphaSense’s delayed filing does not amount to even a procedural error. Unlike

the firm 30-day deadline for filing a removal notice in federal court, the statute “sets forth no

mandatory time period” for notifying the state court about the removal. Knezevich v. Carter, 805

F. App’x 717, 723 (11th Cir. 2020); see 28 U.S.C. § 1446(b)(1), (d). The statute’s only direction

is that the removing party must give the notice “promptly.” 28 U.S.C. § 1446. Here,

AlphaSense notified Superior Court 30 days after it removed the case. Compare Notice of

Removal at 2, with Burns Decl. ¶ 5. While not immediate, that notice was arguably “prompt[].”

28 U.S.C.

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