36.  The proposed Class consists of all current or former African Americans employed at  Comcast’s South Side facility at any time from November of 2007 to the present who have  been subject to discrimination in the terms or conditions of their employment.  Additionally,  the Class consists of all current or former African Americans employed at Comcast’s South  Side facility since January of 2005 to the present, or since prior to that time if the evidence  demonstrates an ongoing continuing violation, who have been subject to a hostile work  environment based on their race.  CLASS IN VIOLATION OF SECTION 1981  139. Plaintiffs repeat and re-allege each and every allegation above as if set forth herein in         full.    140.  Comcast has intentionally discriminated against Plaintiffs and the Class in violation of  Section 1981 by engaging in the following acts 1) forcing class members to work in  substandard facilities which were infested with cockroaches and rats; 2) forcing South Side  employees to install infested and/or defective equipment to its customers and denying them  other necessary equipment and tools required to provide adequate service to its customers;  3) failing to provide training and to promote South Side African American employees into  higher level positions; 4) failing to provide equal pay and fair evaluations to South Side  African American employees; and 5) subjecting South Side African American employees to  hostile work environment by: referring to African American employees in a racially  derogatory manner, applying workplace rules and regulations in a racially biased manner,  falsely assuming that equipment given to African American employees would be stolen,   instructing African American employees to follow different protocol from similarly situated  non-African American employees when placing service calls,  and failing to provide African  American employees with facilities that would allow equal levels of service as to the  facilities of non-African American employees.  DEFINITION OF THE CLASS   THE CLASS IN VIOLATION OF TITLE VII  141. Plaintiffs repeat and re-allege each and every allegation above as if set forth herein in full.    142. Defendant has intentionally discriminated against Plaintiffs and the Class in violation of  Title VII by engaging in the following acts 1) forcing class members to work in substandard  40 facilities which were infested with cockroaches and rats; 2) forcing South Side employees to  install infested and/or defective equipment to its customers and denying them other  necessary equipment and tools required to provide adequate service to its customers; 3)  failing to provide training and to promote South Side African American employees into  higher level positions; 4) failing to provide equal pay and fair evaluations to South Side  African American employees; and 5) subjecting South Side African American employees to  hostile work environment by: referring to African American employees in a racially  derogatory manner, applying workplace rules and regulations in a racially biased manner,  falsely assuming that equipment given to African American employees would be stolen,   instructing African American employees to follow different protocol from similarly situated  non-African American employees when placing service calls,  and failing to provide African  American employees with facilities that would allow equal levels of service as to the  facilities of non-African American employees.  41