30.  PwC has three main channels, or “tracks,” for recruiting and hiring—Campus,  Experienced, and Executive.  PwC fills Junior Associate, Associate, and other entry-level  positions through its Campus track.  The Experienced track recruits applicants for Experienced  and/or Senior Associate and Manager positions.  Plaintiff challenges PwC’s hiring policies and  practices with respect to its Campus track hiring, as well as a portion of its Experienced track  hiring (i.e., non-management Experienced and/or Senior Associate positions).  Executive track  hiring is not at issue here.   32.  In a 2014 Harvard Business Review article, the U.S. Chairman of PwC trumpeted  PwC’s “strikingly young” workforce:  “Because we recruit approximately 8,000 graduates  annually from college and university campuses, two-thirds of our people are in their twenties and  early thirties.  We’ve always employed large numbers of young people.”  According to its FY  2013 U.S. Corporate Responsibility Report, PwC hired approximately 3,200 Experienced hires  and approximately 9,000 Campus hires.  According to a 2016 article in The Atlantic, today PwC  recruits about 11,000 new hires on college campuses each year.      Campus Recruitment Track    33.  PwC offices throughout the country use common employment policies to deter  and screen out applicants ages 40 and older.  The Campus track recruits applicants straight out of  college.  PwC fills entry-level positions such as Junior Associate and Associate through Campus  hiring, and has designated recruiters for different schools.  PwC also hires college students as  interns (who may then be offered entry-level positions).   35.  PwC’s second hiring channel, the Experienced hire track, posts open positions for  Experienced and/or Senior Associates.  Although anyone may apply for positions in this track,  PwC’s unlawful bias against older workers, including its focus on attracting and retaining  “Millennials” and its mandatory early retirement policy, systematically decreases older workers’  chances of being hired.  Due to this bias, PwC intentionally denies applicants ages 40 and older  employment in the Covered Positions because of their age.    Professional Support   37.  According to its FY 2013 U.S. Corporate Responsibility Report, PwC also assigns  interns an associate coach, a career coach, and a relationship partner.    38.  PwC offers all employees coaching, mentorship, and training to provide career  advancement.  PwC employees receive world-class learning opportunities through a system  called “Learning at PwC,” where they have access to an in-depth catalogue of learning programs  and specialized courses.  This training program has been ranked number one for three years by  Training magazine in its “Training Top 125,” which recognizes “the organizations with the most  successful learning and development programs in the world.”  Because of the opportunities it  provides employees, PwC has repeatedly been named as one of the top three places to launch a  career by BusinessWeek.     39.  By disproportionally hiring young applicants, PwC deprives class and collective  members of invaluable professional support that leads to future business and growth  opportunities.  Employment Policies   42.  PwC also intentionally disfavors hiring people 40 years of age or older for the  Covered Positions.  PwC is very proud of its inordinately young workforce.  In order to continue  to attract and maintain “Millennials,” PwC intentionally screens out individuals ages 40 and  older who apply for the Covered Positions and denies them employment opportunities.     43.  PwC also has a mandatory retirement age of 60 for Partners.  As a result,  applicants ages 40 or over are less attractive to hiring personnel because their potential  contributions to PwC appear limited when compared to those of similarly situated younger  applicants.  Because of PwC’s mandatory retirement policy, PwC’s hiring personnel are  disincentivized from hiring applicants 40 years of age or older.   44.  Together, PwC’s uniform employment policies systematically exclude and deter  applicants and prospective applicants ages 40 and older.   Business Opportunities   46.  Accordingly, Plaintiff brings this class and collective action on behalf of himself,  individually, and all similarly situated applicants and prospective applicants ages 40 and older in  the United States.  This action seeks to end PwC’s discriminatory policies, patterns, and/or  practices, and to make the class and collective whole by requesting the following remedies:  injunctive relief to remedy systemic age discrimination; an award of back pay and front pay;  liquidated damages; compensatory and punitive damages; and attorneys’ fees.   47.  Plaintiff brings this collective action pursuant to 29 U.S.C. §§ 216(b), 626(b)  seeking liability-phase injunctive and declaratory relief on behalf of a collective of all applicants  and deterred prospective applicants for the Covered Positions ages 40 and older in the United  States at any time from October 18, 2013 through the resolution of this action for claims under  the ADEA.  Plaintiff also brings this collective action pursuant to 29 U.S.C. §§ 216(b), 626(b)  for monetary damages and other make-whole relief on behalf of a collective of all applicants and  deterred prospective applicants for the Covered Positions ages 40 and older in the United States  at any time from October 18, 2013 through the resolution of this action for claims under the  54.  Plaintiff is a member of the class he seeks to represent.     55.  The members of the class identified herein are so numerous that joinder of all  members is impracticable.  As of June 2015, PwC employs over 208,000 employees worldwide  and approximately 53,000 in the North American region.  Although Plaintiff does not know the  precise number of all applicants and deterred prospective applicants ages 40 and older of PwC,  the number is far greater than can be feasibly addressed through joinder.   57.  The Representative Plaintiff’s claims are typical of the claims of the class.   58.  The Representative Plaintiff will fairly and adequately represent and protect the  interests of the members of the class.  Plaintiff has retained counsel competent and experienced  in complex class actions, employment discrimination litigation, and the intersection thereof.   59.  Class certification is appropriate pursuant to Federal Rule of Civil  Procedure 23(b)(2) because PwC has acted and/or refused to act on grounds generally applicable  to the class, making appropriate declaratory and injunctive relief with respect to Plaintiff and the  class as a whole.  The class members are entitled to injunctive relief to end PwC’s common,  uniform, unfair, and discriminatory policies and practices.   60.  Class certification is also appropriate pursuant to Federal Rule of Civil Procedure  23(b)(3) because common questions of fact and law predominate over any questions affecting  only individual members of the class, and because a class action is superior to other available  methods for the fair and efficient adjudication of this litigation.  The class members have been  damaged and are entitled to recovery as a result of PwC’s common, uniform, unfair, and  discriminatory policies and practices.  The propriety and amount of punitive damages are based  on PwC’s conduct, making these issues common to the class.   70.  Plaintiff incorporates the preceding paragraphs as alleged above.   71.  This Claim is brought by Representative Plaintiff on behalf of himself and the  collective he represents.  Plaintiff has timely filed charges with the EEOC and has thus exhausted  his administrative remedies.  Sixty days have passed since Plaintiff has filed charges with the  78.  Plaintiff incorporates the preceding paragraphs as alleged above.   86.  This Claim is brought by Representative Plaintiff on behalf of himself and the  class he represents.  Plaintiff has timely filed charges with the DFEH and has thus exhausted his  administrative remedies.       87.  PwC engages in an intentional, company-wide, and systematic policy, pattern,  and/or practice of discrimination against applicants and prospective applicants ages 40 and older.   PwC has intentionally discriminated against Plaintiff and the class in violation of the FEHA by,  among other things:  (a)  Utilizing a biased recruitment system that deters prospective applicants  ages 40 and older from applying for the Covered Positions;  (b)  Utilizing a biased recruitment system that excludes prospective applicants  ages 40 and older from applying for the Covered Positions;   (c)  Utilizing a biased recruitment system that discriminates against  prospective applicants ages 40 and older;   (d)  Implementing a mandatory early retirement policy that deters applicants  ages 40 and over from applying to the Covered Positions;  (e)  Implementing a mandatory early retirement policy that causes PwC to  discriminate against applicants ages 40 and over who apply to the Covered  Positions; and  (f)  Systematically and intentionally discriminating against applicants ages 40  and older throughout the hiring process.   88.  These company-wide policies are intended to and do have the effect of denying  Plaintiff and class members employment opportunities because of their age. The discriminatory  acts that constitute PwC’s pattern and/or practice of discrimination have occurred both within  and outside the liability period in this case.     90.  Age is not a bona fide occupational qualification for the Covered Positions.    91.  As a direct result of PwC’s discriminatory policies and/or practices as described  above, Plaintiff and the class have suffered damages including, but not limited to, lost past and  future income, compensation, and benefits.   92.  The foregoing conduct constitutes illegal, intentional discrimination prohibited by  California Government Code section 12940(a).   93.  Plaintiff requests relief as hereinafter described.  Disparate Impact Discrimination  (Age Discrimination in Employment Act of 1967, 29 U.S.C. §§ 623(a)(2))  (On Behalf of Plaintiff and the Collective)   Intentional Discrimination  (California Fair Employment and Housing Act, Cal. Gov’t Code § 12940(a))  (On Behalf of Plaintiff and the Class)   Intentional Discrimination  (Age Discrimination in Employment Act of 1967, 29 U.S.C. §§ 623(a)(1))  (On Behalf of Plaintiff and the Collective)  