Legal Argument: Cisco Systems acknowledges that the caste discrimination lawsuit can be filed under existing anti-discrimination laws. In fact, defendants Iyer and Kompella themselves quote amongst the earliest lawsuit filed based on caste under existing Title VII Federal Laws, more than a decade ago! Cisco’s legal position (misrepresented by activists and misreported by the press) is that this current lawsuit should only be filed under the discrimination categories of race and ancestry as originally alleged by Doe. However, Cisco says that Doe, when he initially complained to the CRD, did not exhaust his allegations of religion, national origin/ethnicity, and color animus, and so the CRD cannot now allege caste-based discrimination on those bases. Cisco rejects the CRD’s attempt to post-facto define caste (a definition that is unnecessary for a caste discrimination lawsuit to proceed under race, ancestry) in a facially non-neutral manner which targets Hindus — as a stand-alone protected category (see Timeline Nov 3, 2020). The CRD’s definition of caste as a stand-alone protected category violates the Equal Protection Clause of the Constitution (See Section I.D)

The CRD claims that Cisco ignored this complaint, a claim that has been weaponized by Dalit activists and in the media. But Cisco also clarifies that they treated this internal complaint as any other anti-discrimination complaint under the existing laws and did not only NOT ignore it but investigated it twice (see Timeline, Nov 3, 2020 – b). Cisco says that they “found no evidence that [Doe] was discriminated or retaliated against on the basis of caste” [Cisco Caste Blog].

The CRD defines caste as an integral part of Hinduism and makes allegations of caste discrimination on behalf of John Doe (a pseudonymous name), whom they identify as an Indian of Dalit caste. The CRD claims that Doe would be bodily harmed if he revealed his true name, and alleged that his two managers Mr. Iyer and Mr. Kompella whom the CRD force-identified as high caste Savarnas or Brahmins were willfully discriminatory, retaliated against Doe, harassed Doe, gave Doe low pay, and hampered Doe’s growth in the organization.

In January 2021, the Hindu American Foundation filed for injunctive relief to prevent the state’s overreach and violation of Hindu American rights, (because the CRD defined caste as an inherent part of Hinduism), under the First and Fourteenth Amendments and California’s Unruh Civil Rights Act. The HAF re-affirmed that caste is already protected under race, ancestry, and other existing categories (see Timeline Jan 7, 2021). HAF stayed neutral, did not take any legal position on the facts of the case.

Cisco’s initial legal defense includes their Motion to Strike [see Timeline Nov 3rd, 2020 – f] the CRD’s use of unscientific surveys from Equality Labs and remove several xenophobic and racially charged comments targeting Hindu and Indian Americans. Judge Drew Takaichi denied the CRD’s motion to put 23+ such irrelevant and xenophobic documents as evidence [see Timeline Feb 11th, 2021].

I.A First Amendment Establishment Clause Violations

The CRD violates the establishment clause (which prevents the government from interpreting religion) of the first amendment in  multiple unique ways and in several instances by interpreting the Hindu religion in State Court. The CRD also repeats these violations in the appeals court. While a state may be allowed to make broad references to a religious practice, the CRD’s attempts to define Hinduism are pervasive and taking into account the additional Freedom from Religion violations [see Section I.B] show their deliberate intent.

1. The CRD interprets Hinduism by defining caste as “a strict Hindu social and religious hierarchy” [CRD Complaint, pg. 2, ln. 5].
2. Further, the CRD ascribes a caste hierarchy to Hinduism by interpreting Brahmin as the highest Hindu religious caste via the combination of the following statements, (a) “Upon information and belief, Iyer is Brahmin” [CRD Complaint, pg. 8, ln. 8], (b) “Defendants, Sundar Iyer and Ramana Kompella are from India’s highest castes  [CRD Complaint, pg. 3, ln. 7].
3. The CRD further ascribes a caste hierarchy and denigrates Hinduism by defining Dalit as the “most disadvantaged people under India’s centuries-old caste system” [CRD Complaint, pg. 2, ln. 5].
4.  The CRD further violates the establishment clause in the following ways:
   • Mr. Suraj Yengde’s declaration [pg. 2, ln. 11] which states, “caste emanates from the Hindu alias Brahmanical books of rule” and makes multiple further references to define Hinduism.
   • Prof. Laurence Simmons’s declaration which incorporates another attempt at defining religion, “caste and untouchability are constructions of Hinduism” [pdf pg. 21, 1st paragraph, Foreward, Religious and Cultural Justice].
   • Thenmozhi Soundararajan’s declaration which defines caste as a “system of religiously codified exclusion that derives from Hindu scripture” [pg.2, ln.14].
5. The CRD further violates the establishment clause by interpreting the relative positions of their alleged definition of Caste within Hinduism as shown below [See I.B.4].

I.B First Amendment Freedom of Religion Violations

The CRD’s Freedom of Religion and Belief violations as shown below were deliberate and intentional as shown in the Motion for Sanctions (See Timeline: Jan 11, 2023).

1. The CRD assumes a Hindu religious identity for an openly irreligious Mr. Iyer (the main manager in the CRD Complaint) even though on his Stanford University page from 20 years ago, he publicly declares, “I don’t profess knowledge of, and have never practiced any [religion]”. Thus, the CRD violates the 1st amendment rights of an irreligious American and the free exercise clause of the first amendment.
2. The CRD perpetuates the caste-by-birth social hierarchy. The CRD presumes a Brahmin caste by virtue of birth on Mr. Iyer, an irreligious American citizen who has actively opposed and never undergone [pg. 1, ln. 14-18] any rite of passage caste marker (‘symbolic sacred thread’) ! This hypocrisy is the very antithesis of what a Civil Rights Department should stand for.
3. The CRD assumes a Hindu religious identity for Mr. Kompella, by assigning him a Hindu religious caste. This despite  their own admission that they did not even bother to verify his religion or caste as this assignment was made ‘upon information and belief‘ [pg. 8, ln. 21].
4. The CRD further pokes into alleged religious doctrine and even attempts to interpret the relative positions of different castes in Hinduism that may exist between a Brahmin and a Dalit by speculating that Kompella’s caste is at least higher than a Dalit (CRD Complaint, pg. 8 ln.21).
5. The CRD fabricates a ‘higher caste’ status for every other team member in the group, “except for Doe the entire team is also from the upper-castes,” [CRD Complaint, pg. 3, ln. 3]. Thus the CRD assigns (without any proof) a Hindu religious status to all these Cisco employees and interprets their alleged religious practices for them violating their First Amendment Rights under the American Constitution. [Note: Public and LinkedIn records even show that many of these employees come from North American, East Asian, and other non-Indian ethnic and cultural backgrounds! Also, see item #6 of Know These Numbers.]

The CRD conspicuously colludes with an openly Hinduphobic activist organization called Equality Labs. The founder of Equality Labs, repeatedly states that “Nazis aren’t Germans in F*king Europe, they’re actually upper-caste Indians“. The CRD uses their data from their unscientific surveys, and in court documents, court declarations, and press releases. While their intent and actions have been exposed (see here), we focus on the data and let it speak for itself.

1. The CRD incorporates the 2016 highly subjective, unscientific, and not randomized Equality Labs survey (as admitted by Equality Labs themselves, see Timeline Nov 2nd, 2020 – c). The CRD racially profiles Hindus and Hindu Americans by claiming alarming statistics like “1 in 4 Dalits have been raped or physically assaulted by upper-caste Hindus in the USA”. This statistic immediately raises red flags. But there are no known police reports about the same, whereas statistically (even accounting for under-reporting of crimes) there should be several 1000s of them. The CRD quotes this data no less than six times in different court motions, between Nov 2020 and Aug 2022 to smear all Hindu Americans (see multiple instances in Timeline, Nov 2020 – e, Mar 2021, May 10th 2022, Nov 2020 – Q3 2022).
2. The CRD racially insults all Dalit Americans by indirectly assuming that tens of thousands of them are incapable of filing a single credible police report alleging rape or physical assault.
3. The CRD further racially stigmatizes Hindu Americans by stating in court documents (see Timeline, Mar 30th 2021-b) without any supporting evidence that “Anecdotal evidence also indicates that Dalit Indians in the United States, once their caste is revealed, have been raped, attacked, and spat upon because of their caste”.
4. The CRD portrays racism by suing defendant Kompella (a brown Indian American) for caste based harassment for asking Doe to file weekly status reports. This despite the decision for requiring weekly status reports having come from Kompella’s manager Tom Edsall (a white American).  This racist assignment of blame to a brown person for a white person’s business function decision is doubly ironic given that CRD  alleges skin color discrimination as a part of casteism (see Timeline, Q2 2018).
5. The CRD’s race baiting of the entire 40+ Cisco team is obvious from their racial prejudice that “supervisors and [and even all] co-workers imported the discriminatory [caste] system’s practices into their team and Cisco’s workplace” [CRD Complaint, pg. 3, ln. 4-5], despite offering no proof to substantiate their claim.
6. The CRD’s intentional race targeting is ironically exposed as Dalits were at the top of the group [see Timeline: Jan 11th 2023 (a), (b), (c)].

The 2020 Carnegie Endowment survey contradicts the CRD’s targeted racism and has shown that alleged caste discrimination is not a significant factor in community interactions among Indian Americans in the USA and is too small to be measured with statistical significance. It also debunks the Equality Labs survey, “This study relied on a non-representative snowball sampling method to recruit respondents. Furthermore, respondents who did not disclose a caste identity were dropped from the data set. Therefore, it is likely that the sample does not fully represent the South Asian American population and could skew in favor of those who have strong views about caste”. Pew Research states that even in India, “Indians in lower castes largely do not perceive widespread [alleged] discrimination against their groups”, in contrast to the alarming rape and physical assault statistics offered by Equality Labs in the USA.

Despite these surveys, and a California judge denying judicial notice (denying to take the Equality Labs survey as evidence—- see Timeline, Feb 11th, 2021) universities like Harvard, California State, and UC Davis continue to rely on Equality Labs (an unknown entity with dubious credentials, whose hateful agenda have been documented here). One should note that surveys do not measure discrimination, they only measure alleged discrimination. The use of these statistics to push for caste-based policies in various institutions in the United States, especially when there are already broad anti-discriminatory laws that offer protection is not only borderline criminal but also unconstitutional, and violates the Due Process and Equal Protection constitutional rights of Hindu Americans.

The CRD, not satisfied with their targeted racism against Hindu Americans, further collaborates and quotes xenophobic comments by Equality Labs. These comments are xenophobic because they generalize hateful caricatures of Indian Americans using anecdotal, anonymous, and unsupportable data. Judge Drew Takaichi (see Timeline, Feb 11 2021) denied judicial notice to all the xenophobic comments below:

1. The CRD  smears all Indian managers in Silicon Valley using anonymous, unspecified, and uncorroborated allegations while concluding that “working with Indian managers is a living hell” (see Timeline Nov 2020 – f).
2. The CRD needlessly smears, politicizes, and attributes an increase in castism and male chauvinism purportedly due to the election of Indian prime minister, Mr. Narendra Modi (ironically known to be from an “underprivileged caste”, and who enjoys widespread support from all “castes” in India— see Timeline Nov 2020 – g).
3. The CRD also tries to perpetrate a dangerous racial narrative by quoting anonymous hearsay that, “dominant caste people in the Indian Bay area community openly boast about their caste privilege and supposed biological superiority” (see Timeline April 23rd, 2021).
4. The CRD attempts to build a racially biased narrative by highlighting the ethnic composition and “over-representation of Indians at Cisco, and in Cisco’s management and professional job categories” (which Cisco has moved to strike off the record, see Timeline Nov 3rd, 2020 (f), Cisco’s Motion to Strike).

As pointed out in Cisco’s and individual defendants’ defense briefs, these repeated attacks on Hindus, Hindu Americans, and the democratically elected head of a foreign country—the Indian Prime Minister Mr. Narendra Modi by the CRD have no relevance whatsoever to the specifics of the case.

IV.A Factual Fabrications

The CRD’s several factual fabrications are exposed from several independent court records and declarations. They are also independently verifiable from public LinkedIn records and google searches.

1. The CRDs claims of Doe being a ‘lone Dalit’ is false [See Timeline: Jan 11th, 2023 (b)].
2. The CRDs claims of the group consisting of ‘entirely Indians’ is false [See Timeline: Jan 11th, 2023 (b)].
3. The CRDs claims of the team members being ‘all upper castes’ is deliberately fabricated [See Timeline: Jan 11th, 2023 (b)].
4. The CRD baselessly alleges that Doe held the ‘lowest status’ in the group [CRD Complaint, pg 3, ln. 9],  despite Doe having had the joint highest grade [Iyer Declaration, Pg.2, line 18] in the group, and was “among the highest compensated members” in the group.
5. The CRD shockingly alleges a ‘hostile to Dalit’ environment, and a ‘Brahmin-Dalit‘ caste hierarchy in the group, despite, (a) All 3 Head positions [pg. 10, ln. 26-28](including Mr. Iyer’s CEO or Overall Head position) were awarded to, and/or accepted by a Meritorious Dalit, (b) Doe’s own supervisor was a Dalit (per California law’s definition of a supervisor, and since a Meritorious Dalit was in a Head position in the group), and, (c) where the only person ever promoted by Mr. Iyer to a senior management position (on par with Mr. Iyer’s grade) in his entire tenure at Cisco (see rows referring to promotion in the Timeline, ‘Q4 2017 – Q1 2018’ & ‘Q1-Q2 2018’), was also a Meritorious Dalit
6. The CRD claims a threat of violence to Doe, by quoting the Equality Labs survey, that “1 in 4 American Dalits have been physically assaulted or raped by upper caste Hindus in the US” to request anonymity for Doe, despite no known complaints of caste-based violence ever filed with the police in the US, and no show of any evidence in the courts of physical threats directed at Doe.

IV.B Extortion

1. The CRD in order to extort Cisco Systems hides that Mr. Iyer as CEO of the internal Cisco startup gave away 100% of his own equity [Pg. 2, line 6] worth several millions of dollars in the startup to his employees, including John Doe.
2. The CRD alleges caste-based salary discrimination for John Doe not receiving a salary increment decision worth a few thousand dollars. The CRD shocks the conscience and makes these allegations despite Doe having been granted by Iyer several millions of dollars in Cisco stock grants [Pg.2, ln. 5].
3. The CRD’s ethics are evident as they make this ‘low pay’ allegations despite Doe having made several million dollars more in compensation than his manager, Mr. Iyer who per court records took zero dollars in stock compensation (see Timeline, ‘Oct-Nov 2015’ & ‘Nov-Dec 2016’).
4. The CRD’s manipulative nature is also apparent as they tie Doe’s lower caste status to his ‘low pay’ claim. This despite stating that 4 of 8 employees (all of whom they forcibly call upper-caste) simultaneously did not receive a raise in Oct. 2016. Thus by their own admission, there were more upper-caste employees who did not receive a raise! [see Timeline, Nov 2nd, 2020 – j].

IV.C Intentional Tampering of Dates

1. The CRD backdates the date of Doe’s initial complaint, to shockingly allege that Mr. Iyer retaliated and denied Doe a raise (“denying him a raise”, CRD Complaint, pg. 14, line 26) in Oct 2016. But Cisco’s demurrer contradicts this allegation, “the only alleged denial of a raise occurred in Oct 2016, before Doe ever complained. Cisco could not have retaliated against Doe for complaints he had not yet made.” [Cisco demurrer, ln 9, pg. 14]!
2. The CRD backdates the date of Kompella receiving the title of Head of Engineering, by alleging that, “With this new title, Defendant Kompella received a raise of approximately, 15% or more” [CRD Complaint, pg. 8, ln 19-22]. But Cisco contradicts the CRD’s allegation,”nor did it [the title] come with any benefits or compensation” [Kompella declaration, page 1, line 23].
3. The CRD pre-dates their date, to claim they served the administrative complaint to Iyer and Kompella, in October 2018 meeting the legally stipulated December 2018 deadline. Cisco contradicts this deceptive claim and shows that this date was fabricated [See Timeline: Nov 2nd, 2020 (h)].
4. The CRD obfuscates dates multiple times, and misleads the court by accusing Cisco of refusing to ‘meet and concur’. But Cisco catches the CRD red handed and proves via written records that the CRD themselves had canceled meetings with Cisco thrice. First on (a) Oct 26th, 2020, then on (b) Oct 29th, 2020, and again on (c) Nov 2nd, 2020 [See Timeline: Feb 24th, 2021].

As of April 2023, the CRD on being served with sanctions (see Timeline, April 10th, 2023) has withdrawn the case against Iyer and Kompella. The sanctions mentioned the following fabricated allegations that the CRD made. The CRD was left with no choice given that the Motion for Sanctions called out the following blatant fabrications:

1. The CRD mocks the judiciary, by claiming that Doe being asked to file status reports (by Tom Edsall, Doe’s 2nd level manager), and being given work assignments (that Doe claims he could not complete) as caste harassment, by co-defendant Mr. Kompella.
2. The CRD claims caste harassment, but never mentions of any particular incident of any bad language or derogatory comments, witnesses to these comments, location or dates and time directed at Doe, despite seven years of employment in Cisco Systems. Cisco’s demurrer [filed Nov 2nd, 2020], requesting such details was ignored by the CRD and John Doe in their March 2021 reply to Cisco’s Demurrer.
3. The CRD alleges that Iyer’s [truthful] comment that, “Doe was not on the main list [at the IIT entrance examination]” [CRD Complaint, pg. 9, ln. 7-10] revealed Doe’s caste, and alleges this as caste harassment. But, “indirectly revealing Doe’s caste to his colleagues, on one occasion, outside of Doe’s presence, in a work-related conversation, and to an unspecified person, does not constitute harassment. Courts have held that statements acknowledging a person’s national origin or background are merely factual statements which cannot be considered harassing or evidence of alleged bias.” [Iyer and Kompella demurrer, Dec 2nd, 2020, pg 10, ln.20-24]. What is worse, is that CRD does not provide us any context on how and when this alleged comment was made by Mr. Iyer. Why is the CRD deliberately hiding the context of a truthful statement?
4. The CRD alleges caste-based harassment by stating that Doe was isolated. But even while Cisco has not had a chance to reply to these allegations in this early stage of litigation, we are able to see that

1. 1. Iyer distanced (isolated) himself from Doe [Iyer declaration, pg. 2, ln. 23],
   2. Kompella states that Doe chose to be insubordinate, confrontational, create a disruptive environment, and had little interest in timely completing tasks [Kompella declaration, ln. 25-28, pg.1] implying that Doe isolated himself,
   3. Cisco’s demurrer [filed Nov 2nd, 2020, pg. 3, ln. 25-26] states that Doe does not dispute “criticisms about his work product, social skills, and insubordination”,
   4. Tom Edsall, Doe’s 2nd level manager, required Doe to file status reports [Kompella declaration, pg.2, ln. 8],
   5. Engineer’s in the team being forced to work around Doe’s neglect of work [Kompella declaration, pg.1, ln. 27-28],
   6. The DFEH’s own complaint acknowledges that Doe had issues with at least four named managers,
   7. A fifth Dalit supervisor who had a Head position (and hence, Doe’s supervisor) was not even interviewed [Motion for Sanctions pg.10, ln. 24-25] by the DFEH! Isn’t that Casteism?
   8. The DFEH’s complaint [pg. 8, ln.27] also references a second Head of Engineering but is silent on that topic,
   9. Doe shockingly chose to extort his classmate and manager, Mr. Iyer [see Section IV.B]

The above, offer glimpses of Doe’s own self-isolation or behavior causing isolation. While we do not take sides, it is clear that the CRD has deliberately hidden the truth, and leaves out important details in order to make these allegations. What is worrying is that the CRD mentions in their complaint that they had two years of investigative and mediation time (to get their facts right). One must note that these caste-based harassment allegations are against Iyer (who actively recruited Doe, despite allegedly knowing Doe’s caste) and Kompella (who did not even know Doe’s caste)!

1. John Doe went to school with Mr. Iyer and claims to know him and has shared social circles with him for 28 years. But, Doe and the CRD knew that Iyer is publicly irreligious for decades as these uncontradicted facts were provided to them at least since 2018 [Motion for Sanctions, pg. 10, ln. 5]. It took us just two minutes of a google search to confirm these facts. Yet the CRD feigns ignorance and deliberately identifies Mr. Iyer as a Brahmin (per the CRD’s definition, ‘a strict Hindu social and religious hierarchy’) thus forcing on an irreligious person a religious Hindu identity.
2. The CRD claims that Iyer knew Doe was a Dalit. But Doe was directly recruited, given the joint highest grade, awarded millions of dollars, in equity by Mr. Iyer, and was also given several leadership positions [Pg. 2, line 20-21] by Mr. Iyer, contradicting the CRD’s claim that Iyer had a discriminatory animus against Doe because of Doe’s caste. As Cisco says, “when same allegedly discriminatory actor previously selected plaintiff for favorable treatment, this creates “an inference of nondiscrimination.” [Cisco Demurrer, pg. 7, ln. 18-19].
3. Recognize that the complainant as a consequence of the generosity of Cisco Systems and Mr. Iyer, is not a poor impoverished Dalit but a millionaire, and was amongst the highest compensated (as mentioned in the Cisco blog) in the form of stock grants and salary while working under Mr. Iyer [see Section IV.B ].

0. ZERO is the number of times John Doe applied for the Head of Engineering Position (that he claims discrimination for), while it was open. Cisco’s demurrer filed November 2nd 2020, shows that Doe didn’t even show interest in the open position, [Ref: line 26-27, pg. 7, “that he ever wanted it”]; Cisco’s demurrer again reconfirms this fact, “or promotion to supervisor or Head of Engineering positions (which he doesn’t allege he requested or wanted)” [Ref: page 10, line 15] .
1. The CRD and John Doe’s claim that he is the ONE and only Dalit in the team is false as described in the Motion for Sanctions [pg. 10, ln. 21-23]. Court records show at least one other self-identifying Dalit candidate with a Head leadership position in the group. Besides, how would the CRD know the caste of every other member in the group to make such a claim, especially when they argue that caste is a highly private matter?
2. The Head of Engineering Position that Doe claims discrimination for was FIRST [Page 2, Line 9-14] offered to another Dalit candidate before Doe complained!
3. In fact, TWO [Page 2, Line 9-14] of these Head Leadership positions were offered to a Dalit Candidate way before Doe even alleged discrimination!! [Motion for Sanctions, pg. 10, ln. 24-29]
4. All top THREE [Page 2, Line 9-14] Head leadership positions like the First Head position, the Head of Engineering position, and the overall Head position were all FIRST offered to and/or accepted by other ‘Dalit’ candidates!!! [Motion for Sanctions, pg. 10, ln. 24-29]
5. As per CRD’s Complaint, Doe had issues with at least FOUR named supervisors. (One of whom, Tom Edsall, a White American who would have absolutely no reason to be aware about caste, let alone Doe’s specific caste) [Motion for Sanctions, pg. 10, ln. 24-29]. A FIFTH unnamed Dalit Head and Supervisor was never interviewed! [Motion for Sanctions, pg. 10, ln. 25].
6. The CRD’s Complaint [Page 3, Line 1-2] claims that the group comprised of ‘entirely Indian employees‘. This is false as described in the Motion for Sanctions [pg. 10, ln. 21-23]. It can also be readily detected from public records which show at least FIVE candidates were of non-Indian origin in the team.
7. The CRD in no less than SIX separate instances, including the trial and appeals court have either accused, nor have retracted that a significant portion of the entire 4+ million Indian American community have physically assaulted or raped 1 in 4 Dalits in America, when their caste was made known to them.
8. A meager FIFTEEN minutes is all that Mr. Kompella was interviewed for by the CRD [Kompella Declaration, Pg. 2, line 17], before the CRD filed suit against him for caste-based harassment, a gross violation of the defendant’s due process rights.
9. The CRD claims John Doe was a victim of salary discrimination even though he received MILLIONS and was amongst the highest compensated (as mentioned in the Cisco blog) in the form of stock grants and salary while working under Mr. Iyer.

With a detailed analysis of facts available in court documents and public websites, we raise the following alarming questions:

1. Is the CRD working with a vested agenda, given that there are many contradictory claims by CRD, a governmental agency?
2. Is the CRD violating its code of ethics and neglecting due process in its hurry to establish that Caste Discrimination in the United States?
3. Is the CRD deliberately violating the Freedom of Religion rights of American Citizens?
4. Why are CRD prosecutors, using Californian taxpayer dollars to repeatedly smear and accuse (six times!) honest Indian Americans of heinous rape and assault, similar to the anti-semitic propaganda, as seen in Nazi Germany?
5. Why is CRD prosecutor, Siri Thanasombat (see timeline, Nov 2020), bullying and smearing all Indian American managers in Silicon Valley, and injecting unrelated Indian political commentary?
6. What should we make of the CRD director Kevin Kish encouraging citizens to lobby California senators on caste (based on the still sub-judice Cisco case), despite his first-hand knowledge that all 3 Head Positions were first offered to and/or accepted by another Dalit candidate?
7. Recent ethical issues at CRD: The EEOC has alleged serious ethical violations by the CRD in October 2021. In 2022 the EEOC has alleged other serious prosecutorial misconduct and contempt of Court by the CRD.
8. Termination of CRD Lead Prosecutors: In April 2021, California Governor fired the CRD lead attorney Janette Wipper (also the lead attorney in the Cisco caste case). The co-lead prosecutor in the Cisco case, Melanie Proctor has also ‘resigned’ as of April 2022.
9. Rampant case filing by CRD in recent times: CRD has filed cases against Silicon Valley Corporates on behalf of employees in various companies including recent cases like Riot Games, Activision, Tesla, etc. If the credibility of CRD becomes questionable due to a lack of factual verification and incorrect allegations, it raises red flags and concerns regarding misuse of public goodwill, political power, and taxpayer dollars.
10. Major Exposés of the CRD: Is CRD driving an agenda against Californian companies extorting millions with increased high-profile cases of alleged gender, caste, and racial discrimination in California, as pointed out by investigative journalist Matt Taibbi, President of the California Policy Center Will Swaim, and extensively covered by Business Attorney, Richard Hoeg from Hoeg Law? (links to all these reports can be seen in the timeline)
11. Motion for Sanctions on the CRD: In January 2023, defendants filed a motion for sanctions against the CRD for filing a legally frivolous complaint with no factual basis [pg.11, ln. 14-15], despite “overwhelming evidence presented by Defendants directly contradicting Plaintiff’s spurious accusations [pg.11, ln.2-3].”

The Media, and activist organizations collaborating with the CRD, are fomenting a lop-sided narrative using allegations as facts and actively hiding the public facts reported in the courts, leading to large-scale deception. Why is it that in the past two years no mainstream media reporter or caste activist has ever skeptically reported (and worse actively hidden) the above sensational facts?

1. Equality Labs founder, Thenmozhi Soundararajan (who is openly Hinduphobic and whose survey the CRD quotes extensively, and who submitted a personal court declaration for the CRD in Nov 2020), who extensively uses the Cisco case to push her caste discrimination agenda, does not appear to have ever acknowledged or communicated the counter facts of the case, in her activist outreach to Universities and DEI bodies in the past two years.
2. The Ambedkar International Center (who penned an Amicus Curiae motion in support of the CRD) quotes from the defendant’s court declarations while being dishonest to Dalits by simultaneously suppressing the truth from the same documents to foster their narrative! Why are Dalit organizations, hiding the truth and abandoning the Silicon Valley success story of the Meritorious Dalit who rose to the top of the group at Cisco Systems, to foster their narrative of Dalit caste discrimination?
3. Mainstream media reporters from Bloomberg, and thewire.in despite having access to open public court records, (and/or quoting) court declarations blatantly hide information that the top 3 Head Positions were awarded to a Dalit in order to build a narrative.  Are mainstream media reporters being silenced by their own bosses?

The CRD’s abusive overreach and Equality Lab’s fabrications inflamed and further catalyzed academia and are the root cause of divisiveness and bigotry. As Americans, we are even more concerned about the lack of skeptical inquiry in Academia, and who make conclusions about caste discrimination without asking for any corroborative data, witnesses, specifics, due process, or empirical evidence.

1. Why does Ajantha Subramanian, a Harvard professor, who extensively quotes the Cisco caste case and gives expert opinions to claim widespread caste discrimination in America, not make public retractions (per academic ethics) despite being made aware of the counter facts of the case? She was informed not just once (per her attendance in the Ambedkar International press briefing), not twice, but at least thrice on separate occasions.
2. Why are Harvard law professors treating the allegations in the Cisco case as facts, and making conclusions on the existence of caste discrimination? Why do these academics not have any skepticism or basic scientific rigor as demonstrated by the Judiciary regarding the several anonymized, unsupportable, heinous caste discrimination claims provided by Equality Labs [see Timeline, Nov 2nd 2020 – f].
3. Have academic standards fallen so low that conferences like Dismantling Global Hindutva Conference (who are inspired by and openly quote the CRD  and Equality Labs) can be used by academics such as Prof. Gajendran Ayyathurai from the University of Gottingen to the platform, identify and target the Cisco managers by name, display their photographs (a criminal offense under German Insult Law 185 StGB, and 22, 33 KUG), group them next to alleged rapists, and make violent comments about them, under the aegis of the University of Gottingen’s Professor and session chair, Rupa Viswanath?
4. Will the University of Gottingen Presidential Board continue to be shamelessly silent when their premises are used by Hinduphobic academics who call upper-caste Indians “agents of Aryanism”?, and stereotype Indians with specific Hindu Brahmin last names (Iyer, Kompella, Trivedi, Sharma and Mukherji) as violent (which includes several of the University of Gottingen’s own faculty, students, and staff), and recklessly denigrate Brahmins by proposing that “Brahminism played a crucial role in the evolution of Nazism itself?”

Fake News: Over 30 opinion pieces on the Cisco case have been published citing allegations as facts in the past two years alone. Hence alarm bells are required to alert as to WHY a government organization like CRD is gunning after Hindu Americans using falsified caste-based allegations.

Rising Activism: Multiple university resolutions and California Democratic party (CADEM) Caste resolution, city council and county resolutions, Santa Clara Human Rights Commission have used the unscientific survey by Equality Labs, and the sub-judice Cisco Caste Case to claim rampant caste discrimination, rampant caste-based violence and to actively push their political agenda based on fabricated insinuations and target Hindu Americans.

Rising Hinduphobia: Vicious narratives are being set through workshops on Caste, through phrases like savarna, Brahminical patriarchy and other stereotypical hate speech used in India by propagandists. In June 2022, Rutgers University published a comprehensive survey on Hinduphobia.

Defamation: The case is sub-judice and will take years to litigate. Meanwhile it has defamed Cisco and its managers publicly and named and shamed using fabricated allegations as facts, calling them vile Brahmins, Savarnas, upper caste and violent in various forums.

Concerned Dalits: Dalit voices and organizations are also a key part of this whistle-blower campaign, and are concerned about how they will be perceived given the sensitivity of this issue. Such use of cry wolf tactics using the judicial system wrongfully will harm honest Dalits. It will harm the case of genuine discrimination if any.

Activists organizations who claim to be Dalit voices do not represent the broader Dalit Bahujan Community in the US. Mainstream Dalit voices have been silenced by these organizations, and we Dalits have also been misled by our own Civil Rights Department.

Concerned Hindu Students: Hindu students are bound to suffer prejudice due to inflammatory caste resolutions (fueled by an unresolved and still sub-judice case, and the CRD’s activist collaborators with questionable data and thin arguments) that smear and single out Hindus inappropriately, especially when there already exists broad anti-discriminatory protections available in California (and the US) law.

Concerned Hindu Americans: Hindu Americans (or those perceived to be Hindus, including South Asian Sikhs, Jains, Muslims, Christians, Buddhists, and others of South Asian origin) are worried about their career prospects, as they get caught in the net of caste-based insinuations and projected as belonging to a religion of inequity. It will tarnish the image of Hindus (and those perceived to be Hindus) and disable trust among coworkers. It will infringe upon the right to freedom of religion and self-identification, and caste-categorize and even criminalize people based on their last names. This alarmingly harks back to the colonial times in India, when people were declared criminals at birth due to their last names, using the Criminal Tribes Act of 1871. Immigrant visa holders (supervisors, managers, co-workers) who are bound to a company per immigration laws are doubly vulnerable to such workplace allegations.

The nuance of last names and categorization as Dalit vs non-Dalit is not known to many Hindu Americans and Indian Americans. So, this witch-hunt for Brahmins and upper-caste (a vague term that has many conflicting definitions) is bound to set a dangerous precedent that will reverberate in the corridors of American companies and have far-reaching repercussions.

Concerned Irreligious Americans: We irreligious Americans (labeled “Nones”) are also part of this campaign, and constitute between 20-30% of the American population. The California Civil Rights Department’s ironical and unconstitutional attempt to define a religious caste identity on an openly irreligious American citizen should be cause for grave concern amongst our almost 100 Million strong irreligious American citizens. Hence the alarm bells.

Concerned Muslim, Christian, Sikh and Jain Americans: The CRD’s xenophobic targeting of Doe’s co-workers include (from public records and LinkedIn data) Muslims, Christian, Sikh and Jain people of Indian, Pakistani, and Sri Lankan backgrounds who worked at Cisco. They have all been racially profiled and accused of importing a discriminatory caste system purely based on their ethnic background [CRD Complaint, pg. 3, ln. 4-5].

Based on the collection of facts, contradictions, and court records listed above, we as American citizens are outraged that the California Civil Rights Department (previously DFEH) suppresses the truth about the one group where all Head positions went to a Dalit, and uses it as caste propaganda, to further their political agenda. It is no surprise that companies are moving out of California (please request access from the California Policy Center to edit and update your company name on the California Book of Exoduses) when the state in the guise of salary discrimination extorts money from a CEO who has given away 100% of his equity to his employees. It appears to be a classic case that shows the opposite of caste discrimination, and an example that “no good deed goes unpunished”. Based on public records, there are several more irregularities in the complaint that we are investigating, from public websites, LinkedIn, and court data.

What can you do? We are bipartisan volunteers who care deeply about the truth, and hate government corruption in America. Anyone is welcome to join us, and send us your first-hand experiences dealing with the California CRD (DFEH) at [email protected]. We welcome all whistleblowers, specifically on the CRD’s unethical behavior over the past decade. You are welcome to tweet @Caste_Gate, mention this website, blog, contact the press, or file complaints at your discretion.

We salute all such honest companies, supervisors, and managers who stand up to the CRD’s bullying and fight for the truth in court. We are not an activist organization. Our focus is to document objective, detailed, specific, verifiable facts, and/or publicly available data. We welcome all corrections, and will promptly fix any mistakes we may have inadvertently made. You are free to use all the materials on this website (which are all from public or court records) with no copyright issues whatsoever.

1. 1. CASTEGATE will only publish publicly available data and is not based on any speculation.
   2. CASTEGATE will not tolerate any ABUSIVE language/behavior, or personal attacks.