17.  Microsoft maintains uniform employment, compensation, performance review,  and promotion policies throughout the United States.  Microsoft also cultivates and promotes a  common corporate culture.    18.  Microsoft’s offices throughout the U.S. use a common organizational structure,  organizing technical employees by levels.   19.  Microsoft discriminates against female technical employees in (1) performance  evaluations; (2) compensation; and (3) promotions.  Performance Evaluations   20.  Microsoft uses uniform, unvalidated, and unreliable procedures for evaluating  employee performance that systematically undervalue female technical employees relative to  their similarly situated male peers.       30.  Plaintiff brings this class action pursuant to Federal Rules of Civil Procedure  23(a), (b)(2), and (c)(4) seeking liability-phase injunctive and declaratory relief on behalf of a  Class of all female technical employees employed by Microsoft in the United States at any time  from September 16, 2009 through the resolution of this action for claims under Title VII.   Plaintiff also brings this class action pursuant to Federal Rules of Civil Procedure 23(a) and (b)(3)  seeking backpay, monetary damages and other make-whole relief on behalf of a Class of all  female technical employees employed by Microsoft in the United States at any time from  September 16, 2009 through the resolution of this action for claims under Title VII.  Plaintiff  reserves the right to amend the definition of the Class based on discovery or legal developments.   31.  Plaintiff also brings this class action pursuant to Federal Rules of Civil Procedure  23(a), (b)(2), and (c)(4) seeking liability-phase injunctive and declaratory relief on behalf of a  Class of all female technical employees employed by Microsoft in the United States at any time  from September 16, 2012 through the resolution of this action for claims under the Washington  Law Against Discrimination.  Plaintiff also brings this class action pursuant to Federal Rules of  Civil Procedure 23(a) and (b)(3) seeking backpay, monetary damages and other make-whole  relief on behalf of a Class of all female technical employees employed by Microsoft in the United  States at any time from September 16, 2012 through the resolution of this action for claims under  the Washington Law Against Discrimination.  Plaintiff reserves the right to amend the definition  of the Class based on discovery or legal developments.   32.  Plaintiff is a member of the Class she seeks to represent.   51.  Plaintiff incorporates the preceding paragraphs as alleged above.   52.  This claim is brought by Plaintiff on behalf of herself and the Class she seeks to  represent.  Plaintiff has filed a timely charge with the EEOC and has thus exhausted her  administrative remedies.    53.  Microsoft has engaged in an intentional, company-wide, and systematic   policy, pattern, and/or practice of discrimination against its female technical employees.   Microsoft has intentionally discriminated against Plaintiff and the Class in violation of Title VII  by, among other things:  a.  Utilizing a biased performance rating system;  b.  Utilizing a biased compensation system;  c.  Utilizing a biased promotion system; and   d.  Failing to take reasonable and adequate steps to prevent and correct the use  of standardless, unvalidated, and/or illegitimate criteria to determine the terms and conditions of  employment.   59.  Plaintiff incorporates the preceding paragraphs as alleged above.   60.  This claim is brought by Plaintiff on behalf of herself and the Class she seeks to  represent.  Plaintiff has timely filed a charge with the EEOC and has thus exhausted her  administrative remedies.   61.  Microsoft’s reliance on illegitimate and unvalidated systems and criteria to  evaluate employee performance, set compensation, and select individuals for promotion, and  determine other terms and conditions of employment, have an adverse impact on female technical  employees in violation of Title VII and are not, and cannot be, justified by business necessity.  Even if such system and/or policies could be justified by business necessity, less discriminatory  alternatives exist and would equally serve any alleged necessity.   66.  Plaintiff incorporates the preceding paragraphs as alleged above.   67.  This claim is brought by Plaintiff on behalf of herself and the Class she seeks to  represent.     68.  Microsoft has engaged in an intentional, company-wide, and systematic   policy, pattern, and/or practice of discrimination against its female technical employees.   Microsoft has intentionally discriminated against Plaintiff and the Class in violation of the  Washington Law Against Discrimination by, among other things:  a.  Utilizing a biased performance rating system;  b.  Utilizing a biased compensation system;  c.  Utilizing a biased promotion system; and   d.  Failing to take reasonable and adequate steps to prevent and correct the use  of standardless, unvalidated, and/or illegitimate criteria to determine the terms and conditions of  employment.   Disparate Impact Discrimination  (Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e et seq.)  (On Behalf of Plaintiff and the Class)   Intentional Discrimination  (Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e et seq.)  (On Behalf of Plaintiff and the Class)   Intentional Discrimination   (Washington Law Against Discrimination, Rev. Code Wash. 49.60.010. et seq.)  (On Behalf of Plaintiff and the Class)  