21.  The individual student plaintiffs bring this action pursuant to Fed. R. Civ. P. 23 (b)(2) on  behalf of themselves and on behalf of a class consisting of all present and future Willamette  female students, including currently enrolled students, students admitted for the 2016-2017  academic year, and prospective students, who participate, seek to participate, or have been  deterred or prevented from participating in or obtaining the benefits of intercollegiate athletics  sponsored by Willamette.    22.  All class members are aggrieved persons under federal civil rights law as a result of  Willamette’s actions, policies, and practices. The named individual student plaintiffs seek  declaratory and injunctive relief on behalf of themselves and all class members to prevent  defendant from engaging in future unlawful conduct and to rectify the effects of present and past  discrimination.   24.  Defendant has failed to provide equal athletic opportunities for women and has provided  more opportunities and better opportunities for male athletes than for female athletes.    25.  For each and every year from 2006 to 2016, defendant Willamette has failed to provide  substantially equal opportunities for its female students. According to Willamette’s own  published reports, the number of female athletes is only about 17 percent of the full-time  undergraduate female population, while male athletes make up about 28 percent of the male  undergraduate population.    26.  Upon information and belief, Willamette’s full-time undergraduate enrollment during the  2015-16 academic year is 1988. Women comprise over 57 percent of the full-time undergraduate  student body, but they account for only about 40 percent of student-athletes.    27.  The percentage of female athletes during the 2015 – 2016 academic year is not  substantially proportionate to the percentage of full-time female students.    28.  Defendant Willamette lacks a continuing history and ongoing practice of expanding  45.  Defendants have failed to meet any of the three criteria for compliance with Title IX’s  equal participation and effective accommodation requirement in violation of 20 U.S.C. § 1681 and  34 C.F.R. § 106.41(c)(1).   46.  The elimination of a viable women’s team places defendant even further out of  compliance with Title IX.   47.  Defendant’s failure to treat female athletes substantially equally with respect to  equipment and supplies, publicity, promotional materials and events, transportation, uniforms,  Athletics at Willamette   COMPLAINT  Violation of Title IX of the   Education Amendments of 1972,   Plaintiffs incorporate by reference paragraphs 1 through 44.    Plaintiffs incorporate by reference paragraphs 1 through 46.   