Handloser v. HCL America, Inc.

CourtDistrict Court, N.D. California
DecidedMarch 9, 2021
Docket5:19-cv-01242
StatusUnknown

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

Bluebook
Handloser v. HCL America, Inc., (N.D. Cal. 2021).

Opinion

8 UNITED STATES DISTRICT COURT

9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN JOSE DIVISION 11

12 GREGORY HANDLOSER and CERAFIN Case No. 19-CV-01242-LHK CASTILLO, individually and on behalf of 13 others similarly situated, ORDER DENYING PLAINTIFFS’ 14 Plaintiffs, MOTION FOR CLASS CERTIFICATION 15 v.

16 HCL TECHNOLOGIES LTD. and HCL AMERICA, INC., 17 Defendants. 18 19 Plaintiffs Gregory Handloser and Cerafin Castillo (collectively, “Plaintiffs”) bring this 20 putative class action against Defendants HCL Technologies Ltd. and HCL America, Inc. 21 (collectively, “HCL”) under Title VII of the Civil Rights Act of 1964 and the Civil Rights Act of 22 1866. Second Amended Complaint, ECF No. 40, at ¶ 2 (“SAC”). Before the Court is Plaintiffs’ 23 motion for class certification.1 ECF No. 163 (“Mot”). Having considered the parties’ 24 25 1 Plaintiffs’ motion for class certification contains a notice of motion paginated separately from the 26 points and authorities in support of the motion. ECF No. 163, at v. Civil Local Rule 7-2(b) provides that the notice of motion and points and authorities must be contained in one document 27 with the same pagination. 1 submissions, the relevant law, and the record in this case, the Court DENIES Plaintiffs’ motion for 2 class certification. 3 I. BACKGROUND 4 A. Factual Background of HCL 5 HCL Technologies Ltd. is an Indian consulting and information technology company, with 6 its headquarters in Noida, India and its United States headquarters in Sunnyvale, California. SAC 7 at ¶ 5. HCL America, Inc. is a wholly-owned subsidiary of HCL Technologies Ltd. and is 8 incorporated in California with its headquarters in Sunnyvale, California. Id. at ¶ 6. The 9 companies operate in the United States to provide consulting and information technology services 10 to clients. Id. HCL has 25 offices and approximately 20,000 employees and contractors in the 11 United States. Id. at ¶ 12; Opp. at 1. 12 HCL contracts with companies based in the United States to supply information 13 technology and consulting services on a project-based model. Id. at ¶ 13. This work can either be 14 completed at HCL’s India-based offices (“offshore”), or at a client’s office or local HCL “delivery 15 center” (“onsite”). Mot. at 2. “Delivery” employees, who make up the bulk of HCL’s workforce, 16 perform direct information technology or consulting services for clients. Opposition, ECF No. 17 171-3 at 1 (“Opp.”); ECF No. 177-5, at ¶ 8 (Ex. A). HCL also hires employees to perform 18 corporate functions like finance and accounting (“enabling” employees) and sales employees. Id. 19 at 2; ECF No. 177-5, at ¶ 8. 20 HCL organizes its “delivery” roles into different lines of business (“LOBs”), such as 21 Engineering Research & Development or IT Infrastructure Management Services. Id. To fill new 22 staffing needs with onsite clients, each LOB is served by a Workforce Placement Cell (“WPC”) 23 that coordinates hiring for new assignments. Id. When an HCL client has a new project, the 24 relevant WPC generally attempts to assign an existing HCL employee who has the relevant skill 25 set and experience for the assignment. Id. If an existing employee cannot be identified to fill the 26 position, then the WPC releases the job request (also called a “demand”) to HCL’s U.S. Talent 27 Acquisition Group (“TAG”) to find a candidate. Defendants assert that they have a preference for 1 staffing onsite projects with “local” candidates, whether those candidates are existing employees 2 or external job applicants. Mot. at 3. Plaintiffs allege that at this stage, Indian candidates with 3 United States visas compete against external applicants from the United States.2 Mot. at 3. 4 Each job request is assigned a “job band” that corresponds to a “Career Level,” with entry 5 level positions falling into Career Levels 1 and 2, and more senior positions falling into Career 6 Levels 3 and 4. Id. TAG seeks external candidates through various sources, including referrals, 7 recruiters, direct applications from candidates, and third-party vendors. ECF No. 177-5, at ¶ 21– 8 24. For external delivery applicants the hiring process generally contains three stages. First, a 9 recruiter from the respective TAG identifies a viable applicant and “screens them through a brief 10 interview.” ECF No. 177-6, at ¶ 5 (Sunil Khanna Decl.). Second, members of the delivery team 11 interview the applicant to assess technical skills and expertise. Finally, the client often interviews 12 the applicant and provides feedback to HCL on whether the client approves of the candidate. Id. 13 The hiring process for sales and “enabling” corporate jobs is different because the work 14 does not involve fix-term assignments for HCL clients, but rather internal work for HCL. As 15 such, WPCs and HCL’s clients are not involved in the selection process for sales and “enabling” 16 roles. ECF No. 177-6, at ¶¶ 7–8 (Ex. B). Sales positions instead generally require the applicant to 17 interview with the Human Resources (“HR”) department. Id. at ¶ 7. Enabling job applicants only 18 go through an HR interview if the position they are being considered for is a “leadership position.” 19 Id. at ¶ 8. 20 Plaintiffs allege that during the hiring process HCL screens local applicants through 21 “culture fit interviews.” Mot. at 6, 15. According to Plaintiffs, “culture fit” is no more than a 22 pretext for screening out non-Indian local candidates. Id. at 7. Plaintiffs do not clarify whether 23 they allege that candidates for all job types receive “culture fit interviews,” but evidence suggests 24 that HR sometimes conducts “culture fit” interviews for sales positions. See ECF No. 161-16 (Ex. 25 13) (“HR discussion is done where the culture fit off [sic] the candidate into the organization . . . 26

27 2 The parties use “Indian” to refer to both Indians and South-Asians. See Mot. at 1; Opp. at 1. The Court therefore adopts this usage. 1 [is] discussed”); ECF No. 162-15, at 2 (Ex. 30) (“You do HR interview to see culture fit”); ECF 2 No. 177-6, at ¶¶ 7–8 (Ex. B) (sales positions regularly involve an HR interview). Plaintiffs do not 3 present evidence that the HR interview for “enabling” leadership positions is used to screen for 4 culture fit. 5 Plaintiffs further allege that HCL employs a uniform, companywide policy regarding how 6 to prioritize candidates for open onsite positions. This prioritization rule allegedly considers 7 candidates in the following order: Prioritization of profiles 8 • Best fit with visa from offshore 9 • Best fit with visa available at onsite • Good fit + up-skilling/cross-skilling from offshore 10 • Flag for recruitment at onsite 11 ECF No. 161-17, at 12 (Ex. 14) (formatting in original). Plaintiffs allege that this prioritization 12 rule means that HCL gives first consideration for open positions to visa-ready Indian candidates, 13 and only considers local United States candidates if no visa-ready Indian candidates are available. 14 Mot. at 4. 15 As Plaintiffs acknowledge, a number of onsite positions that HCL seeks to fill explicitly 16 exclude candidates on visas. Id. at 5. Some positions must be filled by United States citizens or 17 green card holders by law, and other positions are restricted to United States citizens or green card 18 holders because “regulatory pressures” limit the availability of work visas for those roles. Id. 19 1. Discriminatory Effect of HCL’s Employment Practices 20 Plaintiffs submit a report by their expert, Dr. David Neumark, documenting the allegedly 21 discriminatory effect of HCL’s employment practices. Mot. at 8; ECF No. 162-22 (“Neumark 22 Report”); see also ECF No. 162-23 (“Neumark Rebuttal Report”). According to Plaintiffs’ expert, 23 of the approximately 43,000 people that HCL hired in the United States during the proposed class 24 period, 45.68% were Indian, including 41.94% of full-time employees and 59.12% of contract 25 employees.

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Handloser v. HCL America, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/handloser-v-hcl-america-inc-cand-2021.