If you received a NOTICE, it is because Google’s records show that you are or were an employee of Google between September 14, 2013 and July 25, 2022, inclusive, who identified as female and worked in California in one of the job codes covered by this lawsuit. Review the full list of the COVERED POSITIONS for more information.

The Court sent you a Settlement Notice because you had a right to know about the proposed Settlement of a class action lawsuit, and about all of your legal rights and options, before the Court decided whether to approve the Settlement. The Court has approved the Settlement and the Settlement Administrator appointed by the Court has sent the payments that the Settlement allows. T

The Settlement Notice explains the lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for them, and how you get them.

The Court in charge of the case is the San Francisco Superior Court, and the case is known as Ellis v. Google, LLC., Case No. CGC-17-561299. The individuals who sued are called the Plaintiffs and the entity they sued, Google, is called the Defendant. 

The lawsuit claims that Google discriminates against women by paying them less than men for performing substantially similar work in violation of California’s Equal Pay Act, Cal. Labor Code § 1197.5 (“California EPA”) and California’s Unfair Competition Law, Cal. Bus. & Prof. Code section 17200, et seq. (“UCL”) (together, the “Equal Pay Act Claim”).

The lawsuit also claims that Google discriminated against women hired before August 28, 2017, excluding college hires, by allegedly relying on the candidate’s prior pay at time of hire to assign them to lower levels than men with comparable qualifications and experience in violation of California’s Fair Employment and Housing Act, Cal. Gov. Code § 12940 et seq. (“FEHA”) and the UCL (together, the “FEHA Claim”).

Google denies all of the allegations in the lawsuit and maintains that it has fully complied with all applicable laws, rules and regulations at all times. The Court has not ruled on the merits of these claims, has made no findings of fault, and has not awarded damages. The Settlement is a compromise of alleged claims and is not an admission of liability on the part of Google or anyone else. The parties have reached this Settlement in order to avoid the expense, risk and uncertainty of further litigation.

In a class action lawsuit, one or more people called “Named Plaintiffs” or “Class Representatives” (in this case, Kelly Ellis, Holly Pease, Kelli Wisuri, and Heidi Lamar) sue on behalf of other people who they believe have similar claims. All these people are a “Class” or “Class Members.” A court resolves the issues for all Class Members, except for those who exclude themselves from the Class. Judge Andrew Y.S. Cheng is the judge presiding over this class action lawsuit. On May 27, 2021, Judge Cheng certified this case to proceed as a class action and notice was sent to all Class Members at the time, along with an opportunity to opt out of the class action. Everyone who did not opt out at that time is still a Class Member.

The Court did not decide in favor of Plaintiffs or Google. Plaintiffs and Google decided to settle the claims in order to avoid the risks to both sides and the costs of continued litigation, while guaranteeing compensation to Class Members. Plaintiffs and their attorneys think the settlement is preferable to the risks and further costs of continuing the litigation.

If you received a Settlement Notice by email and/or mail to you, it is because you were listed as a Class Member. There are three subclasses certified within this lawsuit, the Equal Pay Act Class, the FEHA Claim Subclass, and PAGA Group Members.

The Equal Pay Act Claim addressing alleged gender pay disparities is on behalf of the following group:

All women employed by Google in a Covered Position in California at any time from September 14, 2013 through July 25, 2022, inclusive, who have not already validly opted out of the certified class in this Action (the “Equal Pay Act Class”). 

The FEHA Claim addressing alleged under-leveling is on behalf of the following group:

All women employed by Google in a Covered Position in California at any time from September 14, 2013 through July 25, 2022, inclusive, excluding campus hires and women hired after August 28, 2017, who have not already validly opted out of the certified class in this Action (the “FEHA Claim Subclass”). 

You are covered by this Settlement if you fall under one of the above definitions and do not exclude yourself from the Settlement.

The Settlement also resolves alleged claims for penalties under the California Labor Code Private Attorney General Act (“PAGA”).

PAGA Group Members are:

All women employed by Google in a Covered Position in California at any time from June 14, 2021 through July 25, 2022, inclusive, regardless of whether they opt out of the certified class of the Settlement (the “PAGA Group Members”). 

PAGA Group Members will receive a PAGA payment regardless of whether or not they opt out of the Settlement

If you received a Notice mailed to you, it is because you were listed as a Class Member. If you are still not sure whether you are included, you can call the Settlement Administrator at 1-888-681-2480 for more information.

The proposed Settlement includes money and business practice changes to resolve pay and leveling claims for the Class. 

The total money paid is One Hundred Eighteen Million Dollars ($118,000,000.00) this total amount is called the “Settlement Fund”. The following items will be paid from the “Settlement Fund” before the distribution of the Settlement Fund to Class Members:

• approximately $135,000.00 in costs of independent settlement;
• $1,000,000.00 in recovery of PAGA penalties to be paid in part to the State of California and in part to Class Members;
• twenty-five percent (or $29,500,000.00) in attorneys’ fees to Class Counsel;
• $1,601,350.65 in reimbursement of litigation and expert costs incurred by Class Counsel to prosecute this case;
• and service awards of $225,000.00 to the Named Plaintiffs in recognition of the time, effort, and risks these individual Plaintiffs took to come forward and prosecute the case.

Separately, Google has agreed to pay an additional $200,000.00 to resolve all of the individual, non-class claims of the Named Plaintiffs and in consideration of their broader release of claims beyond those resolved by the Class. The amount left in the Settlement Fund after the payment of those items is called “the Net Settlement Fund”. This will be approximately $86,000,000.00 and will be allocated to Participating Class Members. The Court will determine the propriety of all payments allocated from the Settlement at final settlement approval. No money will revert to Google. 

The business practice changes are summarized below. (A comprehensive list of these practices can be found in Section VII of the Settlement Agreement, which is available on the IMPORTANT DOCUMENTS page of this website). 

• The retention of an independent expert to conduct an analysis of Google’s process for setting level at hire, and issue recommendations on that process to the extent there are opportunities to make that process more equitable including with respect to gender.
• The retention of an independent expert to conduct an analysis of Google’s pay equity audits and issue recommendations on that process to the extent there are opportunities to more accurately analyze whether employees are paid equitably for comparable work, including with respect to gender equity.
• The retention of an independent external monitor to review Google’s compliance with the terms of the Settlement, including its response to the independent experts’ recommendations.

Initial Individual Settlement Awards were allocated to each Class Member based on an objective formula approved by the Court, which is summarized in Section 9 of the NOTICE and in FAQ 9. 

Please note the amount of your actual Initial Individual Settlement Award may vary slightly from the estimate you were previously provided, based on several factors, including the number of Class Members who excluded themselves, the amount of fees and costs approved by the Court, as well as necessary tax withholdings. All Class Members were sent an Individual Settlement Award unless they excluded themselves from the Settlement.

Second distribution awards were calculated pursuant to section IX.I of the SETTLEMENT AGREEMENT, which says “if the amount of uncashed checks is equal to or more than one and one-half percent (1.5%) of the Total Settlement Amount, the Settlement Administrator will send out a second round of distributions to Participating Class Members in proportion to their first Settlement Shares.”

Of the Net Settlement Fund of approximately $86,000,000.00, forty percent, or approximately $34,400,000.00, will be allocated to the Equal Pay Act Class, and sixty percent, or approximately $51,600,000.00 will be allocated to the FEHA Claim Subclass. 

First the Minimum Payments will be identified.

1. Minimum payments will be allocated to each Class Member. All Class Members for whom Google’s records show a hire date on or after January 1, 2022, will be allocated a flat sum of $250.00 only.
2. All Class Members for whom Google’s records show a hire date on or before December 31, 2021, will be allocated a minimum amount of $500.00, except that those Class Members who worked for Google for fewer than six months during the Class Period will be allocated a minimum amount of $250.00. 

After the Minimum Payments have been identified, additional payments for each Class or Subclass Member for whom Google’s records show a hire date on or before December 31, 2021 are based on the following formulas:

Equal Pay Act Class: (a) a statistical model is used to estimate the alleged difference in total compensation that Plaintiffs contend female Class Members received compared to male employees in the same job code (controlling for attributes like tenure and location); (b) the percentage estimate is then used to estimate an alleged dollar shortfall amount for each Class Member for each year (or fraction of year) worked at Google in a Covered Position in California, based on the average pay of male employees in the Class Member’s job code; (c) interest at 10% per year and what are called “liquidated damages” (i.e., doubling of damages and interest) are added; and (d) there is an additional amount (15 days of wages, or 50% of the penalty claimed by Plaintiffs) added for Class Members who left Google before the end of the period covered by the data.

FEHA Claim Subclass: (a) a statistical model is used to estimate the average probability that a female employee was hired into a lower job level than a male employee hired into the same job family, accounting for prior education and a measure of employment experience; (b) a statistical model is used to estimate the percentage pay differences associated with each successive higher job level within each job family; (c) this percentage pay difference is applied to the average pay of male employees in each job family and level, to estimate the potential alleged underpayment Plaintiffs contend is a result of leveling; (d) based on each Class Member’s job family and job level, the estimated probability of being allegedly under-leveled and the estimated underpayment are multiplied to compute the average amount by which each Class Member was allegedly underpaid by being hired into a lower job level; (e) each Class Member is credited this alleged underpayment amount for each year or fraction of a year the Class Member worked at Google; and (f) interest at 10% per year is added to this amount. Participating FEHA Subclass Members will obtain settlement shares both as FEHA Subclass Members and EPA Claim Class Members.

Each Class Member’s total estimated settlement share is calculated as a percentage of the total alleged damages experienced by all Class Members as estimated by the Plaintiffs, and applied proportionally to the Net Settlement Fund (see Section 7 in the Notice). A full and complete explanation of how settlement shares are calculated can be found at Exhibit C to the Settlement Agreement available for review and download on the IMPORTANT DOCUMENTS page of this website. 

In addition to the calculations above, the Settlement also allocates $1,000,000.00 for PAGA penalties, of which the State of California retains $562,500.00, with up to $250,000.00 paid in attorneys’ fees. The remainder, or approximately $187,500.00, will be distributed pro rata to “PAGA Group Members” which means all women employed by Google in a Covered Position in California at any time from June 14, 2021 through the date on which the Court grants preliminary approval of the Settlement, regardless of whether or not they have validly opted out of the certified class in this Action or whether or not they opt out of the Settlement. PAGA Group Members will receive a PAGA penalty payment regardless of whether they opt out of this Settlement.

Once this process is completed, the Settlement Administrator issued Initial Settlement Award checks, less applicable tax withholdings.

Second distribution awards were calculated pursuant to section IX.I of the SETTLEMENT AGREEMENT, which says “if the amount of uncashed checks is equal to or more than one and one-half percent (1.5%) of the Total Settlement Amount, the Settlement Administrator will send out a second round of distributions to Participating Class Members in proportion to their first Settlement Shares.”

To qualify for a payment from the Settlement, Class Members did not need to do anything. Class Members automatically received a payment unless they excluded themselves from the settlement. The releases and benefits are detailed in the Long Form Notice.

Initial Settlement checks were sent out to Class Member’s via First Class Mail on January 26, 2023. Second Distribution awards were sent out to eligible Class Member’s April 15, 2024.

The Court held a hearing on October 24, 2022, to decide whether to approve the settlement. Judge Cheng approved the settlement. The appeals period has passed, and the Settlement is now considered “Effective.”

Initial payments were sent out from Seattle Washington, via First Class mail on January 26, 2023. These initial payments became void on July 25, 2023. Section IX.I of the SETTLEMENT AGREEMENT notes that any funds remaining from the initial distributions uncashed awards is to be used to send a second round of distributions to those Settlement Class Members who participated in the Settlement by cashing their initial checks. As such we can no longer reissue initial payments in this matter.

A second distribution was mailed on April 15, 2024 to eligible Class Members. If you were sent a Second Distribution award, and you have not received your check by April 30, 2024, please contact the Settlement Administrator for instructions on how to get your check reissued.

You may check this website or call 1-888-681-2480 anytime for updates or questions. The Settlement Administrator will make multiple efforts to ensure Class Members cash their checks.

Initial Settlement Award Checks became void one hundred eighty (180) days after they were initially issued or on July 25, 2023.

Pursuant to Section IX.I of the SETTLEMENT AGREEMENT if the amount of uncashed checks is equal to or more than one and one-half percent (1.5%) of the Total Settlement Fund, the Settlement Administrator will send out a second round of distributions to Participating Class Members in proportion to their first Settlement Shares. Therefore, a second round of distributions was sent to all eligible class members who participated in the Settlement by cashing their initial checks. The Second Round Award Checks become void one hundred eighty (180) days after they were initially issued or on October 12, 2024.

After this if any funds from uncashed checks remain in the Total Settlement Payment, then it will be sent to cy pres recipient Equal Rights Advocates, a non-profit organization dedicated to advancing the rights of women. No money will revert to Google.

In exchange for receiving a payment under the settlement, you will not be able to sue, continue to sue, or be part of any other lawsuit against Google for the same claims that are the subject of this lawsuit (unless you exclude yourself from the Settlement). The exact language of the release is as follows:

All Class Members who do not timely opt out will release any and all known and unknown claims against Google and the Released Parties that arise out of or relate to the allegations in the Second Amended Complaint that the Court certified for class treatment, including the allegations that, from September 14, 2013 through the date upon which the Settlement is preliminarily approved, Google paid women in Covered Positions less than it paid men for substantially similar work, that Google assigned women to lower levels than it assigned men, and that Google failed to pay all wages due to employees upon their separation of employment. The released claims include but are not limited to claims brought under California Labor Code sections 201-203, 1197.5, 2698 et seq., California Business and Professions Code sections 17200 et seq., California Government Code section 12940 et seq., and the Industrial Welfare Commission Wage Order. Such claims include claims for wages, statutory penalties, civil penalties, or other relief under the California Labor Code, PAGA, relief from unfair competition under California Business and Professions Code section 17200 et seq., relief under California Government Code section 12940 et seq., attorneys’ fees and costs, and interest, and waiver of the protection of California Civil Code section 1542 with respect to such claims (the “Class Members’ Released Claims”).

If you did nothing, you automatically were issued the payment to which you are entitled under the Settlement and will release your claims against Google. The releases and benefits are detailed in the Long Form NOTICE and in FAQ 13.

If you did do not want a payment from this Settlement, but you wanted to keep the right to sue or continue to sue Google on your own and at your own expense, about the legal issues in this case, then you needed to take steps to exclude yourself.

You needed to mail your exclusion request to the Settlement Administrator, postmarked no later than October 11, 2022, or submit it online no later than October 11, 2022. This deadline has now passed and excluding yourself is no longer an option. 

PAGA Group Members will receive a PAGA payment regardless of whether or not they opt out of the Settlement.

If you are a Settlement Class Member, and did not exclude yourself by the October 11, 2022 deadline, you give up the right to sue Google for the claims that this Settlement resolves. If you have a separate pending lawsuit regarding the claims at issue in this case, speak to your lawyer immediately. 

No. If you excluded yourself, you will not receive money from this Settlement. But, you may sue, or continue to sue, in a different lawsuit against Google, at your own expense.

If you are a Class Member, you were able to object to the Settlement if you did not think it should be approved. To object, you needed to send a letter to the Settlement Administrator via mail or email, postmarked no later than October 11, 2022, or submit your Objection Form online by October 11, 2022. This deadline has now passed and objecting or commenting is no longer an option.

Objecting is simply telling the Court that you don’t think the Settlement should be approved. You can object only if you stay in the Class. Excluding yourself is telling the Court that you don’t want to be part of the Class. If you exclude yourself, you cannot object because the case no longer affects you, and you will not receive any payment from the Settlement.

The Court appointed the following law firms as Class Counsel to represent the Class:

These law firms are called “Class Counsel.”  If you want to be represented by your own lawyer, you may hire one at your own expense.

You do not need to hire your own lawyer because Class Counsel are working on your behalf and you do not need to do anything to receive benefits under the Settlement. You also may exclude yourself or object without a lawyer. If you want your own lawyer, you may hire one, but you will be responsible for any payment for that lawyer’s services.

Class Counsel was granted a payment of 25% of the Settlement Fund for attorneys’ fees and $1,500,000.00 in reimbursement for litigation and expert expenses Class Counsel already incurred in prosecuting your claims. The Court approved the propriety of the requested award.

The Court held a Fairness Hearing at 3:00 p.m., Pacific on October 24, 2022, to consider whether the Settlement is fair, reasonable, and adequate, and decided whether to approve the Settlement. You had the option to attend and to ask to speak. At the hearing Judge Cheng approved the Settlement. The appeals period has passed, and the Settlement is now considered “Effective.” The Settlement Administrator has sent payments in accordance with the terms of the Settlement. These payments were issued to Class Members on January 26, 2023, via First Class Mail.

You may check this website or call the Settlement Administrator at any time for update or questions. The Settlement Administrator will make multiple efforts to ensure Class Members cash their checks.  

Yes. The NOTICE only summarizes the proposed Settlement. More details are in the full Settlement Agreement. You can get a copy of the Settlement Agreement by visiting the IMPORTANT DOCUMENTS page of this website.

Or the official docket of the case may be inspected at the Office of the Clerk of the San Francisco County Superior Court, located at 400 McAllister Street, San Francisco, CA 94102, during the Court’s regular business hours (8:30 a.m. to 12:30 p.m.).

You can also view the OFFICIAL DOCKET at the Court’s website, which is free to use.

You can review and download the Judgment by visiting the IMPORTANT DOCUMENTS page of this website. 

In addition to reviewing this website, you can contact the Settlement Administrator by telephone at 1-888-681-2480 or by email at Info@GoogleCAPaySettlement.com, for more information about the case and the Settlement. You may also contact Class Counsel with questions. You may also seek the advice and counsel of your own attorney at your own expense, if you desire.

Google provided the Settlement Administrator with your most recent address based on its corporate records in order to mail your Notice and benefit check. If you have moved since you last worked for Google, please provide the Settlement Administrator with your current mailing address by either mailing or emailing a letter requesting your information be updated. Please be sure to provide your initial address of record, as well as your updated address information. This is necessary to verify your identity and ensure the proper record is being updated.

Please note that all updates and changes to individuals records may take some time to be reflected in our systems. Please be patient. 

If your name is spelled incorrectly on your NOTICE or if your name has changed since you worked for Google, you will need to update this information directly with the Settlement Administrator. 

To correct a misspelling of your name, please mail or email a letter to the Settlement Administrator, with:

1. the incorrect name spelling,
2. the correct name spelling,
3. the address on record, and

4. a copy of government-issued ID.

To update your record with a legal name change please mail or email a letter to Settlement Administrator, with:

1. your previous name spelling,
2. the new name,
3. the address on record,
4. a copy of government-issued ID, and

5. a copy of the legal document showing the name change (marriage license, divorce decree, etc.).

Please note that all updates and changes to individuals records may take some time to be reflected in our systems. Please be patient.