(42 U.S.C. § 1981)   10.   P&G intentionally discriminates against non-citizen applicants for employment in  the United States on the basis of alienage by utilizing a facially discriminatory policy and/or  practice that categorically denies employment to non-citizens who are authorized to work in the  U.S., but who are not U.S. permanent residents, refugees, or individuals granted asylum.   11.  P&G further subjects non-citizen applicants for employment in the United States,  on the basis of alienage, to additional requirements that are not imposed on U.S. citizen  applicants, and rejects the non-citizen applicants who cannot satisfy the additional requirements.   12.  In October 2013, P&G denied Mr. Rodriguez’s application for an internship with  the company on the basis of these policies and/or practices, even though he was legally  authorized to work in the United States.     13.  On or around December 5, 2012, Mr. Rodriguez was granted an Employment  Authorization Document (“EAD”) pursuant to DACA.     14.  On or around September 2013, Mr. Rodriguez attended an on-campus information  session at FIU advertising P&G’s internship program.  Eduardo Moreno, a P&G recruiter and  FIU alumnus, and Jose Nuñez, an FIU student who had completed a P&G internship and worked  as a company Campus Ambassador, hosted the information session.      15.  During the information session, Mr. Moreno discussed the various types of  internships P&G offered and informed the attendees that the internships were paid, were  approximately 10 to 12 weeks in duration, and could be based in either Cincinnati, Ohio or  Boston, Massachusetts.     17.  After the information session, Mr. Moreno handed out his business card and  instructed the attendees, including Mr. Rodriguez, to send him their resumes so that he could  review the resumes and give the attendees advice about obtaining an internship with P&G.   18.  The P&G Campus Ambassador, Jose Nuñez, also collected the attendees’ contact  information, including Mr. Rodriguez’s, and later emailed them a sample of P&G’s assessment  exam, which is part of the internship application and was discussed in the information session.    19.   Later that night, Mr. Rodriguez sent Mr. Moreno his resume, expressed his desire  for a P&G internship, and requested input on his resume.   20.  A few days later, Mr. Moreno emailed Mr. Rodriguez with some pointers for his  resume.   21.  After receiving Mr. Moreno’s input and making revisions to his resume, Mr.  Rodriguez went to P&G’s career website, www.experiencePG.com, selected an internship  application for P&G’s Finance and Accounting Department, uploaded his resume, and answered  the company’s pre-screening questionnaire.   23.   Mr. Rodriguez correctly responded “No” to each of the above questions.  He then  completed the rest of the pre-screening questionnaire and submitted it to P&G through its  website.    24.  According to the information given to attendees at the FIU information session,  the next step in Mr. Rodriguez’s application process was for him to complete two types of  assessment tests online, which should have been sent to him as a web link via an email from  P&G following the submission of his application.    25.  Mr. Rodriguez never received the expected web link to P&G’s assessment tests.   After a week of waiting, he emailed both Mr. Moreno and Mr. Nuñez and inquired about the  status of his application.  Mr. Moreno responded via email and instructed Mr. Rodriguez to  correct his graduation date on his online application and re-submit it to P&G, as Mr. Rodriguez  had erroneously indicated that he would graduate from FIU on the Fall of 2014 instead of the  Winter of 2014.    26.  Mr. Rodriguez revised his online application and then emailed P&G’s  Recruitment Team on October 3, 2013, explaining that he needed to revise his graduation date.   He also requested clarification of the company’s immigration status criteria.  Mr. Rodriguez’s  email explained that he possessed a valid work permit and did not need employer sponsorship to  work lawfully in the United States.   27.  A day or two after sending his email to P&G’s Recruitment Team, Mr. Rodriguez  received an internship rejection letter from P&G via email.   29.  In addition to P&G’s immigration status screening questionnaire and Mr.  Moreno’s statement regarding P&G’s policy and/or practice, some P&G job postings specifically  warn under the “Qualifications” section that “[c]andidates must be a U.S. citizen or national,  refugee, asylee or lawful permanent resident.”  36.  Plaintiff brings his class allegations under Fed. R. Civ. P. 23(a), (b)(2), (c)(4) and  (b)(3) on behalf of a class defined as follows:  All non-citizens, who are within the jurisdiction of  the United States and legally authorized to work in the United States, who were denied  employment with P&G in the United States under the company’s policies and/or practices for  hiring non-citizens, between July 17, 2013 and the date of judgment in this action (the “Class”).     37.  Plaintiff is a member of the Class.   38.  Upon information and belief, the members of the Class are so numerous that  joinder of all of them is impracticable.  P&G has offices throughout the United States, USCIS has  approved over 1.3 million initial and renewal requests for DACA, and there are thousands of  other individuals who, despite having work authorization, do not meet P&G’s requirements for  46.  Plaintiff incorporates by reference the allegations in all preceding paragraphs.   47.  Plaintiff brings this claim on his own behalf and on behalf of the Class.   48.  Plaintiff is a person within the jurisdiction of the United States.   49.  Plaintiff is an alien.    50.  Plaintiff is legally authorized to work in the United States.    51.  P&G has discriminated against Plaintiff and the Class on the basis of alienage by  rescinding or denying them contracts to work or deterring them from work opportunities because  they are not U.S. citizens, permanent residents, refugees, or individuals granted asylum by the  United States.    52.  P&G’s intentional discrimination against Plaintiff and the Class has interfered  with their right to make and enforce work contracts.    53.  Defendant’s facially discriminatory policy and/or practice of denying work  opportunities to Plaintiff and the Class based on their alienage, despite their legal authorization to  work in the United States, has harmed Plaintiff and the Class and constitutes unlawful alienage  discrimination in the making and enforcing of contracts in violation of 42 U.S.C. § 1981.   55.  Defendant’s conduct has caused, and continues to cause, Plaintiff and the  members of the Class substantial losses in earnings and other work benefits. 