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The Publicly Known Timeline Of The Cisco Caste Discrimination Case

The Public Timeline Of The Cisco Caste Discrimination Case

The bizarre facts that point to the California Civil Rights Department’s (CRD, previously DFEH) corruption

1 Sep 2015   The co-defendant Mr. Iyer incubates an internal startup at CISCO. Mr. Iyer is the Co-founder, overall Head, and CEO of the startup. Mr. Iyer’s LinkedIn, Mr. Iyer’s Bio.
2 Oct 2015  (a)   Mr. Kompella the co-defendant along with several others are hired by Mr. Iyer as ‘Principal Engineers.’ Mr. Kompella’s LinkedIn.
3 Oct 2015 (b) Same Actor Inference John Doe is personally solicited (in part due to his long-standing relationship with Doe as a batchmate at the Indian Institute of Technology) and hired as a ‘Principal Engineer’ by Mr. Iyer despite his alleged knowledge of Doe’s caste. The DFEH would later file a caste discrimination claim directly contrary to Same Actor Inference. As Cisco later explains, “When same allegedly discriminatory actor previously selected plaintiff for favorable treatment, this creates an inference of nondiscrimination” [Cisco Demurrer, pg. 7, ln. 18-19]. Iyer Declaration, pg. 2, ln. 3 and DFEH Complaint.
4 Oct-Nov 2015 Same Actor Inference John Doe and other principal engineers report directly to Mr. Iyer, and are given the joint highest grade in the group. Mr. Iyer generously bequeaths 100% of his CEO equity worth several million dollars to all his employees, including to John Doe. John Doe receives millions worth of equity in this process due to this decision by Mr. Iyer. Iyer Declaration, pg. 2, ln. 3-8.
[Also: Motion for Sanctions, pg. 10, ln.16.]
5 Nov 2015 – 2016 Same Actor Inference In this period, John Doe is offered multiple leadership opportunities by Mr. Iyer showing nondiscriminatory intent (see: Same Actor Inference). Doe’s performance or lack thereof is not known from the current public court records. Iyer Declaration, pg 2, ln. 18-21.
6 Q3 2016   Mr. Iyer solicits for the first Head position within the Group/startup and awards it to a meritorious self-identifying Dalit candidate (further referred to as Meritorious Dalit to distinguish him from the Dalit plaintiff, John Doe.) Iyer Declaration, pg 2, ln. 11-12.
[Also: Motion for Sanctions, pg. 10, ln.24-28.]
7 Q3 – Q4 2016 (a)   Mr. Iyer solicits the second Head position of Engineering and also awards this Head position initially to the Meritorious Dalit. Meritorious Dalit presumably refused this second Head position because Mr. Iyer eventually offers the position to Mr. Kompella (co-defendant in the CISCO case). Iyer Declaration, pg. 2, ln. 12-13.
[Also: Motion for Sanctions, pg. 10, ln.24-28.]
8 Q3 – Q4 2016 (b) Unethical / Sanctionable / Hiding Material Evidence John Doe does not apply for the open Head of Engineering position. Note: Later on, the CRD would shockingly hide this fact from the judge and claim discrimination for Doe not being awarded the Head of Engineering position. Cisco Demurrer (filed Nov 2, 2020), ln. 26, pg. 7, “that he ever wanted it”. Also ln. 15, pg. 10, “which he doesn’t allege he requested or wanted”.
9 Nov 2016   Mr. Kompella is offered Head of Engineering as part of a comprehensive organizational change.  DFEH Complaint [pg. 8, ln. 19-21]
Cisco Demurrer [‘teamwide reorganization’ pg.10, ln. 19]
10 Nov 21st 2016 Unethical / Sanctionable / Hiding Material Evidence John Doe files a Dalit caste discrimination complaint with CISCO HR, claiming discrimination for not being awarded the Head of Engineering position. It is important to note that this position was first offered to the Meritorious Dalit! The DFEH hides this fact (despite their knowledge since 2018 [pg. 10, ln. 5]) from the judge in their June 2020 complaint. DFEH Complaint.
11 Nov-Dec 2016 Unethical / Sanctionable / Hiding Material Evidence John Doe files for caste-based salary discrimination for not being awarded a few thousand dollars of salary increment in October 2016, despite Mr. Iyer having given his entire CEO equity (which amounted to millions of dollars) to all his employees including John Doe, who as a result was making several millions of dollars more than his CEO, Mr. Iyer. Cisco Demurrer and Iyer Declaration.
12 2016-2018 (a)   John Doe files several internal complaints with CISCO HR complaining of caste discrimination, harassment, and retaliation. After multiple reviews by independent HR personnel, these allegations were found unsubstantiated by Cisco Systems. DFEH Complaint, Cisco Demurrer [pg. 3, ln. 12-15], and Cisco Caste Blog para. 5.
13 2016-2018 (b)   Mr. Iyer continues to champion Meritorious Dalit for his career growth, in addition to having awarded him Head leadership positions in the past. Between the Q4 of 2017 and Q1 of 2018, Mr. Iyer also offers his title of the overall Head (CEO) to the Meritorious Dalit. Iyer Declaration, pg. 2, ln. 14.
14 Q4 2017 – Q1 2018   Defendant Iyer “recruited, mentored, and promoted meritorious personnel who self-identified as Dalit, including within the current group at Cisco.” [Opposition to  DFEH’s Motion to Proceed Using a Fictitious Name, pg. 4, ln. 12-13]. Also, LinkedIn records and Mr. Iyer’s declaration [pg. 2, ln. 9-14] show that Iyer promoted this Meritorious Dalit to a senior management position after Meritorious Dalit does not accept the title of the overall Head of the group (CEO). Mr. Iyer and Mr. Kompella’s Opposition to Plaintiff California DFEH’s Motion to Proceed Using a Fictitious Name, filed 1/12/2021, ln. 12-13, pg. 4.
15 Q1 – Q2 2018   Mr. Iyer transitions out of the group after the internal start-up is absorbed by CISCO, and also to distance himself from Doe. Mr. Kompella takes over as the interim Head of the group. DFEH Complaint, Cisco Demurrer, and Iyer Declaration (pg. 2, ln. 23-24.)
16 Q1-Q2 2018   Mr. Iyer has not promoted anyone other than Meritorious Dalit to a senior management position in his entire tenure at Cisco (since even Mr. Kompella, the alleged ‘Brahmin’ co-defendant, and the interim Head of the group, is only promoted a full year later in 2019, after Iyer left the group.) Mr. Kompella’s Linkedin.
17 Q2 2018 Unethical / Sanctionable /
Mr. Kompella asks John Doe for weekly status reports on request from his manager Tom Edsall. Two years later the DFEH sues Kompella (not Edsall, a white American) for caste-based harassment [pg. 13, ln. 7]. And despite Doe not having filed [Kompella Declaration, pg. 2 ln. 2-11.] any internal complaint alleging caste-based harassment on this matter. DFEH Complaint and Mr. Kompella’s Declaration [pg. 2 ln. 2-11.]
18 May 2018   Mr. Gupta is appointed as the new overall Head of the group. DFEH Complaint, pg. 11, ln. 4-5.
19 Q3 2018   Mr. Gupta rates John Doe as deficient in 6 out of 8 criteria and does not award him the position of Director of Research Operations. DFEH Complaint, pg. 11, ln. 6-12.
20 Jul 2018 (a)   On not being awarded the position of Director of Research Operations, John Doe claims this as retaliation by Mr. Iyer and files a complaint to Cisco HR. The DFEH would later support this purely conclusory [pg. 14, ln. 3-7] retaliation claim, despite Mr. Iyer having already transitioned out of the group 6 months ago. DFEH Complaint, pg.11, ln. 2-7.
21 Jul 2018 (b)   John Doe files an administrative complaint with DFEH, a governmental body. DFEH Complaint, pg. 5, ln. 9-17.
22 Oct 2018   Doe files a revised administrative complaint with DFEH in October 2018 naming defendants Mr. Iyer and Mr. Kompella DFEH Complaint, pg. 5, ln. 9-17.
23 2018-2020   DFEH becomes aware of all the facts through its 2-year long investigation and mediation. The DFEH’s knowledge of uncontradicted facts since 2018 is also re-confirmed by the defendants in their Motion for Sanctions [pg. 10, ln. 5]. DFEH Complaint, pg. 5.
24 June 30th 2020 (a)
[Refiled: Oct 16th 2020]
Frivolous / Sanctionable / Hiding Material Evidence DFEH files the lawsuit alleging Dalit caste discrimination in a group hiding the uncontradicted fact [Motion for Sanctions, pg. 10, ln. 5] that all THREE Head positions were first offered to another Meritorious Dalit! The DFEH later refiles the case in State court in October 2020. DFEH Complaint.
[Also: Motion for Sanctions, pg. 10, ln.26-28.]
25 June 30th, 2020 (b) [Refiled: Oct 16th 2020] Fabrications DFEH alleges that, ‘except for Doe, the entire team are also from the high castes in India’. Court records will later [Motion for Sanctions, pg.10, ln. 5] show these claims of Doe being a  (1) a ‘lone Dalit’ who worked in a group consisting of, (2) ‘entirely Indians’, of, (3) ‘all upper castes’ were deliberately fabricated despite knowledge to the contrary by the CRD since 2018.  DFEH Complaint [pg. 3, ln.1-3] and Motion for Sanctions
26 June 30th 2020 (c)
[Refiled: Oct 16th 2020]
Unethical DFEH also alleges salary discrimination by Iyer, for Doe not getting a few thousand dollars in salary increment in Oct 2016, despite Iyer having awarded Doe several million dollars in stock grants, and having sacrificed 100% of his CEO equity to his employees, including to Doe. These are the DFEH’s tax-payer-funded ethics. DFEH Complaint, ln. 9, pg. 3 and ln. 6, pg. 10.
27 June 30th 2020 (d)
[Refiled: Oct 16th, 2020]
Constitutional Violation of First Amendment The DFEH in their complaint defines caste, as a “strict HINDU social and religious hierarchy”. The DFEH in their complaint assigns Mr. Iyer a Hindu caste. This is malicious as the DFEH knew since 2018 as “these uncontradicted facts were provided to Plaintiff during the investigation of Doe’s administrative complaint” [pg. 10, ln. 5-6]. They would also have known from public data, that Mr. Iyer is publicly irreligious for decades, violating an American citizen’s right to freedom of religion under the 1st Amendment. DFEH Complaint, Iyer’s Stanford Webpage, Iyer Declaration.
[Also: Motion for Sanctions, pg. 10, ln.4-5.]
28 June 30th 2020 (e) Spurious
The DFEH in a press-hungry move immediately publicizes their lawsuit, while also claiming from the Equality Labs (self-acknowledged, unscientific) survey that “67% of Dalits reported being treated unfairly at their American workspaces”. Judge Drew Takaichi would later discard [See Timeline: Feb 11, 2021] this spurious survey. DFEH press release.
29 June 30th 2020 (f) Tampering with Dates DFEH misleads the court and claims without attaching any proof that they served the legal charges (Service of Process) to Mr. Iyer and Mr. Kompella in October 2018 meeting the legally stipulated December 2018 deadline. DFEH Complaint, pg. 5, ln. 21-22.
30 June 30th 2020 (g) Fabrication The DFEH claims that the defendant Kompella, ‘with the new title of Head of Engineering, received a raise of approximately 15%’. But court records show, that this title did not ‘come with any additional benefits or compensation’. Mr. Kompella’s Declaration [pg. 1, ln. 21-23]
31 October 16th, 2020 (a)   DFEH voluntarily dismisses their federal court complaint, and re-files in state court. for tactical reasons, to avoid arbitration. Cisco Demurrer
pg. 1, ln 6-7, and pg. 6, ln. 12.
32 October 16th, 2020 (b) Racial Profiling DFEH files a motion to anonymize Doe making claims that, “Dalit Indians in the United States, once their caste is revealed, have been raped, attacked, and spat on because of their caste” [pg. 6, ln. 16-18]. The DFEH would later repeat these rape allegations in their Writ Petition in the appeals court in March 2021. Motion to Proceed Using a Fictitious Name
33 Oct 27th, 2020 Contradiction DFEH claims that Doe’s caste status is private and submits Doe’s declaration, “I do not share my caste with others, even my close friends.” [Doe Declaration, pg.2, ln.2]. However, Doe then contradicts himself and the DFEH twice in his own declaration. (1) He states, Iyer was aware of his caste because they attended [the Indian Institute of Technology] at the same time.” [Doe Declaration, pg. 2, ln. 26] (2) He also states “a lot of my classmates [in school] knew about my caste …” [Doe Declaration., pg. 2, ln. 3-4.] John Doe Declaration.
34 Nov 2nd, 2020 (a) Contradiction DFEH also submits Mr. Yengde’s declaration [pg.3, ln. 25] which contradicts the caste privacy claim by the DFEH by stating that caste can be inferred from one’s last name and other public markers. Yengde Declaration.
35 Nov 2nd, 2020 (b) Speculation DFEH alleges a risk of retaliatory physical or mental harm to Doe via Doe’s declaration, “I am deeply concerned that Cisco, Iyer, and Kompella will publicly disclose my identity to people in our professional and social community” [Doe Declaration, pg. 3, ln. 6], and also claims a possibility of such harm via his shared social network with Mr. Iyer [Doe Declaration, pg. 3, ln. 7-9]. Judge Takaichi would later rule that as speculation [pg. 4, ln. 25] not evidence. John Doe Declaration.
36 Nov 2nd, 2020 (c) Unscientific Evidence Equality Labs (a group founded by openly Hinduphobic activist Thenmozhi Soundararajan) formally attempts to add their self-acknowledged, unscientific, web survey on caste into the record. By Equality Lab’s own admission, “it is unclear whether the Caste distribution in our survey reflects the actual distribution of Caste groups of South Asians in the diaspora, or that some groups disproportionately participated.” Equality Lab plainly states that there is “no existing data . . . to correlate [the report’s] findings.” [Opposition to  DFEH’s Motion to Proceed Using a Fictitious Name, pg. 4, ln. 25] Thenmozhi Soundararajan Declaration and Equality Labs Survey, Nov 2nd, 2020 [pdf pg. 24, ln.3; pdf pg. 23, ln.9].
37 Nov 2nd, 2020 (d) Irrelevant Evidence The DFEH even requests the judge to take judicial notice of this unscientific survey! They also request notice of press articles, many of which are irrelevant to the case or simply repeat the allegations in the Cisco case … driven by the plaintiff’s own media outreach.  DFEH Request for Judicial Notice, filed Nov 2nd 2020.
38 Nov 2nd 2020 (e) Racial Profiling The DFEH repeatedly smears Hindu Americans, and quotes from the unscientific survey, unbelievable statistics (contradicted by the absence of any police records) that, “found that in America, 1 in 4 Dalits surveyed experienced physical assault“. Equality Labs doubles down on this claim quoting “26% of Dalits who responded said that they had faced physical assault in the United States based on their caste”. Equality Labs Survey [pdf pg. 34, ln. 1-3; also pdf pg. 28].
39 Nov 2nd 2020 (f) Xenophobia The DFEH attorney, Siri Thanasombat, smears all Indian managers, by filing as “evidence” a statement by 30 women in Silicon Valley, claiming to be Dalit, who anonymously accuse their Indian managers of unspecified casteism, without naming any specific incident, without naming their alleged casteist managers or co-workers, without giving any specifics of any casteist comments directed on them, without location, date, time or any details or any collaborating witnesses while concluding that “working with Indian managers is a living hell”. Note: Judge Takaichi would later (see Timeline, Feb 11th 2021) rule this as not evidence. Dalit Women Statement, incorporated in Siri Thanasombat Declaration, pg. 21, Nov 2nd 2020. Also available in The Washington  Post.
40 Nov 2nd 2020 (g) Xenophobia CRD needlessly politicizes and attacks Indian Prime Minister Modi by claiming “an increase in male chauvinism after the election of Indian prime minister, Modi” (ironically known to be from a “lower caste”, and who enjoys widespread support from all “castes” in India). Note: Judge Takaichi would later (see Timeline, Feb 11th 2021) rule this as not evidence. Dalit Women Statement, incorporated in Siri Thanasombat Declaration, pg. 22, Nov 2nd, 2020. Also available in The Washington  Post.
41 Nov 2nd, 2020 (h) Tampering with Dates Cisco contradicts the DFEH’s deceptive claim (feigning to the judge) of timely service of process by stating, “Moreover, Iyer and Kompella were not served with the charge on October 9, 2018. Instead, they were not served with the charge until late March 2019”. In the interim 2 years, the DFEH has not produced any evidence to the contrary. Cisco Demurrer, pg. 4, footnote 4.
42 Nov 2nd, 2020 (i) Tampering with Dates
DFEH claims that Doe complained and hence Mr. Iyer retaliated and denied Doe a salary raise. Cisco counters this  deceptive cause-and-effect claim, by stating, “that the only alleged denial of a raise occurred in October 2016, before Doe ever complained. Cisco could not have retaliated against Doe for complaints he had not yet made.”
Cisco Demurrer, pg. 14, ln. 8-9.
43 Nov 2nd, 2020 (j) Contradiction DFEH’s makes an self-contradictory, manipulative claim that Doe (while being compensated in millions) was denied a few thousands of dollars raise due to his ‘lower-caste’, despite stating that 4 of 8 employees (all of whom they forcibly call upper-caste) simultaneously did not receive a raise. Thus by their own admission, there were more upper-caste employees who did not receive a raise! Cisco Demurrer, pg. 7, ln. 21-22.
44 Nov 2nd, 2020 (k) Inconsistency Doe makes a vague reference to Iyer making a discriminatory comment about a Muslim candidate. However, public records show that Iyer recruited a senior Muslim co-founding engineer on his team. Iyer  recruited this Muslim candidate in his previous start-up and also previously at Cisco Systems. Public records show Iyer also recruited two other senior Muslim candidates into the same Cisco team; Mr. Iyer also offered executive  or co-founder positions to Muslims from Bangladesh, Iran and Pakistan in his previous startups. DFEH Complaint, pg. 9, ln. 4.
45 Nov 3rd, 2020 (a) Same Actor Inference Cisco challenges DFEH’s caste discrimination allegations stating “Iyer actively recruited and hired Doe to work with him in a highly coveted position at Cisco earning top compensation, even by Silicon Valley standards. (When same allegedly discriminatory actor previously selected plaintiff for favorable treatment, this creates “an inference 0f nondiscrimination”). Cisco Demurrer, pg. 7, ln. 15.
46 Nov 3rd, 2020 (b) Inconsistency Cisco mentions, “As Doe acknowledges, Cisco, which does not tolerate discrimination of any sort, investigated Doe’s contention. Doe further acknowledges that, at Doe’s request, Cisco conducted a second level [independent] review 0f the investigation’s findings”. Thus Doe’s self-acknowledgment is inconsistent with DFEH’s claim that Cisco ignored Doe’s complaints and failed to recognize casteism [pg. 10, ln. 13-15]. Cisco Demurrer, pg. 1 ln. 16-18
Also, see Cisco Caste Blog
47 Nov 3rd, 2020 (c) Unsupported,
Cisco counters that the CRD [despite 5 years since Doe was employed] makes conclusory claims [pg. 9, ln 24; pg. 13, ln 24], where no specific actions are pled [pg. 9, ln. 25], while “vaguely referencing, unspecified discriminatory comments”. Cisco Demurrer.
48 Nov 3rd, 2020 (d) Inconsistency Cisco’s Demurrer [pg. 10, ln.16] mentions that DFEH “cannot point to ANY  event where his [Doe] caste was mentioned or referenced, [other than the truthful acknowledgement of Doe’s IIT rank]”. Defendant Iyer also mentions that his several generous actions towards Doe do not align with Doe’s allegations, and specifically about Iyer making ANY statement about Doe being from a scheduled caste. Mr. Iyer and Mr. Kompella’s Opposition to Plaintiff California DFEH’s Motion to Proceed Using a Fictitious Name, pg. 2 ln. 3-12.
49 Nov 3rd, 2020 (e) Unethical CISCO releases a blog giving a clean chit to Mr. Iyer and Mr. Kompella, and also expresses dismay at the highly unusual tactic of naming the managers, “who would face abuse on social media with no chance to be heard or defend themselves.” Further, Cisco mentions that DFEH and Doe have insisted on keeping Doe’s identity confidential, a courtesy neither he nor the DFEH extended to the defendants. This bullying tactic by the DFEH is all the more unethical given the now public facts of this case. Cisco Caste Blog.
50 Nov 3rd, 2020 (f) Xenophobia / Irrelevant Evidence Cisco defends its Indian employees, and files a motion to strike CRD’s immaterial broad-based allegations attacking Indians, including (1) The “ethnic composition of Cisco’s workforce” and the alleged “over-representation of Indians” at Cisco, (2) The usage of H1-B visas, and (3) alleged Caste Discrimination By “Non-Parties Against Non-Parties” in India based on “hearsay and absence of evidentiary support” as irrelevant to this case. Memorandum Of Points And Authorities In Support Of Motion To Strike Portions Of Plaintiff’s complaint” by Cisco Systems, pg.10-11.
51 Q4 2020 Evasion / Hiding Key Evidence Cisco requests judicial notice, but the DFEH refuses to share a copy of John Doe’s original administrative complaint filed in 2018. What is the DFEH hiding from the court and the public? Cisco Demurrer, pg. 4, footnote 4, 5.
52 Jan 7th 2021 Constitutional Violation of First Amendment Since, the DFEH defines caste, as a “strict HINDU social and religious hierarchy”, the Hindu American Foundation (HAF) files for injunctive relief to prevent the state’s overreach and violation of Hindu American rights under the First and Fourteenth Amendments and California’s Unruh Civil Rights Act. The HAF stays neutral to the allegations in the case itself. HAF Motion to Intervene & HAF Website, DFEH Complaint, pg. 2, ln. 6
53 Jan 12th 2021 (a) Unsupported,
Cisco insinuates wrongdoing by the DFEH, via their actions, which are, “based on unsupported, conclusory allegations that DFEH well knows from its investigation cannot be sustained”.

Cisco Opposition to Fictitious Name, pg. 4, ln. 2-3.

54 Jan 12th 2021 (b) Constitutional Violation of First Amendment The DFEH perpetuates “caste-based stereotypes forcing a caste system [on individual defendants] based on birth, not beliefs”. This also violates the First Amendment. Iyer Kompella Opposition, pg. 12, ln. 13.
55 Feb 11th, 2021 Irrelevant
Judge Drew Takaichi, denies the CDFEH’s motion to put into judicial notice their 23+ documents which consist of irrelevant evidence — several media articles and opinion pieces (many with circular references back to the Cisco case), a US Dept. of State report, etc., and also denies judicial notice of the unscientific Equality Labs survey.

Re: Motion to Proceed Using Fictitious Name, filed Feb 11th, 2021, pg. 4 ln. 5-11.

56 Feb-Mar 2021 Specious Judge Drew Takaichi, denies the CDFEH’s motion to proceed with a fictitious name, calling out the CDFEH’s motion as specious, and the evidence submitted by Doe for retaliatory physical harm as speculation. The DFEH appeals this verdict and files a Writ petition. Re: Motion to Proceed Using Fictitious Name, filed Feb 11th 2021, pg. 6 ln.11.
57 Feb 22nd, 2021 Defamation / Irony In contrast to the HAF’s neutrality on the specifics of the case, The Ambedkar International Center, files an Amicus Curiae, personally attacking defendant Iyer by speculating, “Higher—caste workers sometimes view lower—caste workers such as John Doe who benefit from affirmative action programs as incompetent and undeserving … That attitude is evident in the case before the court: John Doe’s Cisco supervisor told colleagues that Doe was “not on the main list” at one of India’s universities.” This while fully aware (as they quoted declarations of the defendants) that Iyer gave all his top THREE Head positions first, to a Meritorious Dalit. Application to file Amicus Curiae pg. 5, footnote 22.
Also, see screenshot.
58 Feb 24th 2021 Tampering with Dates The DFEH misleads the court by accusing Cisco of refusing to ‘meet and concur’ [DFEH Opposition, pg. 3, sec. 4(A)] to dismiss Cisco’s demurrer. But emails between Cisco and the DFEH (J. Liburt Declaration, Pg 1-3, referencing Exhibit D, E filed Nov 3rd, 2022) show that the DFEH themselves moved or canceled meetings with Cisco thrice on separate independent instances before Nov 2nd 2020, exposing the DFEH’s deceitful claims. DFEH Opposition to Demurrer, filed Feb 24th, 2021, pg. 3.
59 March 2021 Racial Profiling The DFEH repeats their previous smears of Hindu Americans quoting again, “that in America, 1 in 4 Dalits surveyed experienced physical assault” in their Writ Petition to the Court of Appeal, Sixth Appellate District. Petitioner’s reply iso Writ [pg.17.] also see Screenshot.
60 Mar 30th 2021 (a) Deception The DFEH’s Writ petition to contest their request for anonymity (quoting Doe’s declaration) states that defendant Iyer spoke about Doe’s caste to Doe’s ‘shared social circles’ [DFEH Writ Petition, pg. 38]. But this deceptive narrative built upon treating allegations as facts are contradicted by Doe’s own declaration (pg. 3, para. 13, filed Nov 2nd, 2020) which merely speculates about his shared circles (as also pointed out in the trial court judge’s ruling on Feb 11th, 2021). DFEH Writ Petition, filed Mar 30th, 2021, 6th Court of Appeals, pg. 38.
61 Mar 30th 2021 (b) Racial Profiling The DFEH ascribes collective guilt and generalizes their previous claim that “Dalit Indians in the United States, once their caste is revealed, have been raped, attacked, and spat on because of their caste” [DFEH Petition for Writ of Mandate, pg. 38, footnote 11], this time offering a single unconfirmed, uncorroborated [news article] with an anonymous accuser as proof!

The US isn’t safe from the trauma of caste bias

62 April 23rd 2021 (a) Xenophobia CRD prosecutors, Janette Wipper and Melanie Proctor racially divide Hindus by quoting without any evidence the Equality Labs report “Dominant caste people [in U.S. tech networks and the Indian Bay Area community] openly boast about their caste privilege and supposed biological superiority.” The CRD repeats this propaganda (reminiscent of similar propaganda against the Jews in Nazi Germany). Pg. 21, para 2, Petitioners Reply to Writ Filed on April 23rd, 2021, California Court of Appeal 6th Appellate District Case H048962.
63 April 23rd 2021 (b) Unethical The CRD in requesting anonymity for Doe goes to great lengths to state that “Caste is a matter of highly sensitive and personal nature“. This reveals the CRD’s unethical nature and double standards as the CRD openly revealed the individual defendants’ names and their alleged or perceived castes. Pg 19, para 2, Petitioners Reply iso Writ Filed on April 23rd, 2021, California Court of Appeal 6th Appellate District Case H048962.
64 May 12th 2021 Unethical DFEH Director Kevin Kish encourages a change.org petitioner, Aditi Ramaswamy to lobby California senators on caste, using the as-yet sub-judice Cisco case as a basis for Dalit discrimination, while unethically not being honest to her, that all Head positions, in this group, went to a Dalit. Update to Aditi Ramaswamny’s Petition.
Also, see screenshot.
65 Oct 2021 Conflict of Interest The EEOC (a federal government organization) alleges serious ethical violations by the DFEH in October 2021, including a repeated violation of the California rules of professional conduct, and by failing to isolate DFEH attorneys who had a conflict of interest. California DFEH accused of ethics violations in Activision Blizzard lawsuit.
66 Q4 2021- Q1 2022 Contempt of Court In 2022, the EEOC alleges other serious prosecutorial misconduct and behavior contemptuous of court by the DFEH. The company Activision also joins the EEOC and seeks an ethics review against the DFEH. Later, the judge would deny the DFEH from intervening in the case, but the DFEH in contempt of court would attempt to intervene multiple times despite the court ruling. The YouTube channel by the Hoeg Law firm has several detailed videos on the public charges against the DFEH. EEOC FALLOUT: Activision Seeks Ethics Review of ENTIRE CA Lawsuit, Also: California, Central District Court, Case No. 2:21-CV-07682-DEF-JEM.
67 April 2022   In April 2022, per reports, the California Governor fired the DFEH lead attorney Janette Wipper (also the lead attorney in the Cisco caste case). The co-lead prosecutor Melanie Proctor in the Cisco caste case has also ‘resigned’ as of April 2022. DFEH Lawyers Gone | Gov Accused of “Interference”.
68 Q1-Q2 2022 Constitutional Violation of Due Process Tesla releases a blog complaining about the DFEH’s class action racial discrimination lawsuit, despite no finding of cause by the DFEH in over 50 complaints, and also files an official complaint with the OIG.

The DFEH’s misguided suit.

69 May 10th, 2022 Racial Profiling CRD’s attorney Michelle Lee urges the appeals court to twice reconsider and add the Equality Labs survey (which includes the claim that 1 in 4 Dalits have been physically assaulted or raped by Upper Caste Hindus in the United States), and later again take into consideration Thenmozhi Soundarajan’s Declaration on her EQ Labs Survey. Oral Arguments, Sixth District Court of Appeal (Timestamp: 1:52:50, and 2:23:25)
70 May 10th, 2022 Deception Michelle Lee also says that there is nothing in the records except for the defendant saying that they do not discriminate. In light of the Motion for Sanctions, this statement is grossly deceptive. Oral Arguments, Sixth District Court of Appeal
71 May 14th 2022 Unethical An investigative journalist, Matt Taibbi (now famous for The Twitter Files governments expose), releases a multipart article detailing the historical background of unethical prosecutorial behavior from 2013 onwards, including Janette Wipper’s (the now fired chief DFEH prosecutor of the Cisco caste case) actions in the Oracle, Google lawsuits. “The Lawyers Who Ate California”, Part 1, Part 2, Part 3.
72 May 2022 Unethical Will Swaim, from the California Policy Center, suggests that the CRD “has gone rogue and the [California] Governor [Gavin Newsome] is trying to rein it in.” He also calls the DFEH a tyrant, and details the history, and background of the multiple serious issues within the DFEH covering the DFEH’s behavior with Activision, Tesla, and Riot games. California’s anti-business campaign is evident in the war against Activision – Orange County Register.
73 Nov 2020 – Q3 2022 Racial Profiling The DFEH smears the entire Indian American community for a sixth consecutive time (since their anonymity motion in Nov 2020) in the appeals court on May 10th, 2022 that ‘upper-caste’ Indian Americans have physically assaulted or raped 1 in 4 American Dalits in the United States just on knowledge of their Dalit caste. This allegation without any evidence in police records statistically tarnishes the reputations of Indian Americans. California Court of Appeal, Case H048962.
74 Jun 2021 – Q3 2022 Defamation The DFEH conveniently ignores the now available scientific Pew research caste survey (June 29th, 2021) or the Carnegie Endowment Indian American survey (June 9th, 2021) for their caste data, but continues to defame Hindu Americans quoting from the unscientific Equality Labs survey. Attitudes about caste, Pew Research.
Social Realities of Indian Americans, Carnegie Endowment Survey.
75 Aug 5th 2022   The appeals court denies Cisco’s motion to compel arbitration. It asks judge Takaichi from the trial court, to review the evidence for the DFEH’s anonymity motion for Doe, and take into consideration evidence (if any) that Doe may have submitted of any specific threat of bodily harm to his family members in India. California Court of Appeal, Case H048962.
76 Sep 2022   The DFEH changes its name to the Civil Rights Department (CRD).  It remains to be seen whether the new name would cause any change in their denigration of Hindu Americans (amongst others) going forward. California Civil Rights Department.
77 Sep 22nd 2022 (a) Constitutional Violation of First Amendment The Hindu American Foundation (HAF) sues Kevin Kish, the director of the California Civil Rights Department (CRD) ironically for the CRD’s violations of Hindu-American Civil Rights encompassing violations of Free Exercise of Religion, Denial of Procedural Due Process and Denial of Equal Protection. HAF’s Federal lawsuit in the US Eastern District Court of California.
78 Sep 22nd 2022 (b) Constitutional Violation of Due Process TESLA independently also counter sues the California Civil Rights Department (CRD) ironically for the CRD’s violations of TESLA’s Due Process Civil Rights, which includes the same lawyers as in the Cisco case. TESLA’s allegations that the CRD did not interview TESLA management have similarities with the CRD’s meager 15-minute interview with Mr. Kompella before filing suit against him in the Cisco case. TESLA’s counter lawsuit in the Superior Court of The State of California, Alameda County.
79 Oct 19th 2022 Constitutional Violations Two professors file under Section 1983  a Civil Rights lawsuit against the Chancellor Jolene Koester, and Trustees of the California State University (CSU) for targeting Hindus by adding ‘caste’ in their interim policy, citing constitutional violations of the First Amendment, Equal Protection (referencing California’s definition of caste in the Cisco case). They also cite a Due Process ‘Void for Vagueness’ violation due to the unconstitutionally vague definition of caste and raise serious concerns about the “stereotypes and implicit bias” that the CSU Policy perpetuates. US District Court (Central District Court of California)
Kumar, Sinha vs. California State University.
80 Dec 30th, 2022 (a) Evasion CRD appears to be burying their egregious behavior in this case from public scrutiny by approaching Cisco for confidential mediation (which Cisco has accepted), contrary to CRD’s past efforts to hastily publicize the case in the press, lobbying senators, and in their repeated opposition to arbitration. Case Management Statement [Pg. 4, Sec. 16c] filed by Cisco systems on 30th December, 2022.
81 Dec 30th, 2022 (b)   It appears that “CRD has agreed to voluntarily dismiss individual Defendants pending approval of the Director of the CRD (Kevin Kish).” This concession by the CRD is indicative of and exposes the past egregious behavior of CRD prosecutors Janette Wipper, Melanie Proctor, and Siri Thanasombat in this case. Defendants threaten to file a Motion for Sanctions if the CRD does not voluntarily dismiss the case against them. Case Management Statement [Pg. 5, Sec. 18] filed by Iyer, Kompella on 30th December 2022.
82 Jan 11th, 2023 (a) Frivolous /
Defendants file a Motion to Sanction the CRD, for “filing a legally frivolous complaint [pg.11, ln. 14-15]”, despite “overwhelming evidence presented by Defendants directly contradicting Plaintiff’s spurious accusations [pg.11, ln.2-3].” Motion for Sanctions, filed Jan 11th, 2023.
83 Jan 11th, 2023 (b) Fabrications Defendants allege an improper purpose (to harass or to cause unnecessary delay or expense) by the CRD. They present several uncontradicted facts [Motion for Sanctions, pg.10, ln. 5] that were known to the CRD since 2018 including disproving fabricated claims of Doe being a ‘lone Dalit’, the group consisting of ‘entirely Indians’, and ‘all upper castes’. Motion for Sanctions.
84 Jan 11th, 2023 (c) Fabrications
Erasure of Dalit Identity
Defendants state that the CRD did not even bother to interview the Dalit Head in the group (talk about casteism!). This further counters the CRD’s fabrications of allegations ‘of a caste hierarchy’ and a ‘hostile to Dalit environment’ [Motion for Sanctions pg.10, ln. 24-25] since all Head positions were already offered or accepted by a different Dalit. Besides, Doe was given the joint highest grade, awarded millions of dollars in equity, and offered multiple leadership positions [Iyer Declaration, Pg. 2, line 20-21] by Mr. Iyer. Motion for Sanctions,
Iyer Declaration.
85 April 10th, 2023 Withdrawal
On being threatened by sanctions by the defendants for fabrication of evidence, the CRD withdraws their complaint against both defendants, Iyer and Kompella. Contrary to their past actions to keep this in the Court, the CRD approaches CISCO, yet again, for mediation (to keep their fabrications of public scrutiny).

Dismissal filed by the CRD.

Press Release by Foxrothschild for Dismissal of claims.

86 April 12th, 2023 Damning Expose The California Policy Center releases a report stating that Bounty Hunter incentives has made the California’s Civil Rights Department (CRD), fund its budget through attorney fees and has created a monster. Enforcing Civil Rights: Does a Regulator’s Profit Motive Benefit the Public Interest? by Steve McCarthy.
87 April 15th, 2023 Misleading While Castegate does not take any position on SB-403, the Caste Equity Task Force pens a letter to the Senate Judiciary Committee making no reference to the poignant details of the Cisco caste case. Letter from the caste Equity Task Force, pg. 2.
88 April 24th, 2023 Contradiction / Unconstitutional While Castegate does not take any position on SB-403, the Caste Equity Task Force claims that “whether you identify with it or not, if you are born into a caste-based society, a level of caste will always be attributed to you, regardless of whether you identify with it or not”. Thus, a plaintiff is allowed to self identify into a perceived caste while a defendant can be force identified by the generous Stasi (Oops CRD)! Letter from the caste Equity Task Force, pg. 1-2.
89 April 26th, 2023 Trial by Media While Castegate does not take any position on SB-403, Senator Wahab references the sub-judice Cisco case as proof, holding several Cisco co-workers in her own constitutency (Silicon Valley, Senate District 10), as guilty without due process in court. Thus, also demonstrating contempt for the Judiciary! Senator Wahab misleads the Senate Judiciary Committee and presumes guilt before innocence.
90 April 26th, 2023 Fabrication / Manipulation While Castegate does not take any position on SB-403, Senator Wahab  fabricates a non-existent Google case as proof while introducing her Caste Discrimination Bill! Senator Wahab misleads the Senate Judiciary Committee.
91 April 26th, 2023  Self-contradiction While Castegate does not take any position on SB-403, Senator Wahab contradicts the CRD and California textbooks by stating that her Bill to explicitly introduce the word caste “does not target a specific community nor religion”. This despite California textbooks and the CRD repeatedly insisting on equating caste to Hinduism for several years. Senator Wahab makes a self-contradictory claim.
92 April 26th, 2023 Racial Profiling While Castegate does not take any position on SB-403, Senator Wahab racially targets Indian Americans by amplifying the language of Equality Labs, accusing them of discrimination in restaurants, housing, technology, and other industries without offering any empirical data. Senator Wahab’s racially charged comments  based on anecdotal, unsupported heresy.
93 April 26th, 2023 CRD Overreach While Castegate does not take any position on SB-403, we note that Senator Wahab promises to handover (“and follows the CRD’s authority for enforcement of these violations”) the enforcement of alleged caste discrimination in California to the CRD’s already abusive overreach on caste! Senator Wahab’s unintentional strengthening of CRD’s abusive enforcement.
94 May 4th, 2023 Irony The Department of Justice funds and Governor Newsom unintentionally hands over the “CA vs Hate” hotline to the abusive CRD! The CRD’s mocks their own definition of a hate incident by their repeated racial profiling and xenophobic remarks on Indian Americans.
95 May 7th, 2023 Unconstitutional Discriminatory Intent While Castegate does not take any position on SB-403, Senator Wahab is seen collaborating multiple times and seems to have been misguided by an openly Hindu hating Equality Labs. Senator Wahab is misguided by Equality Labs founder Thenmozhi Soundararajan.
96 June 1st, 2023 Contradiction District Attorney, Jeff Rosen contradicts Senator Wahab’s claim in the Senate Judicial Committee, of caste leading to widespread rape, assaults and other criminal behavior. Santa Clara District Attorney’s comments.
97 June 8th, 2023 CRD Corruption At least 30 employees of Cisco Systems have penned an open letter to the (CRD) addressing its deeply concerning case against Cisco Systems by highlighting the severe dishonesty displayed by the CRD, which they believe unfairly racially targeted both them and their employer. It also highlights how CRD’s case has damaged the image of businesses employing people of South Asian immigrant backgrounds and has made it difficult for them to be in Silicon Valley. Open Letter by several Cisco engineers against CRD’s corrupt actions.
98 June 12th, 2023 CRD’s Corruption Senator Josh Becker, tweets about the “state’s role in this [Cisco] case”, and states that, “many troubling issues have been pointed out” Senator Josh Becker’s tweet, also see screenshot.
99 July 5th, 2023 Unconstitutional Discriminatory Intent Legal Analyst from the Assembly Judicial Committee , Tom Clark, acknowledges that Equality Labs is the primary sponsor of SB403. The judicial committee does not even question the openly Hinduphobic and discriminatory intent (a key constitutional violation) of the Bill’s primary sponsor, and founder Thenmozhi Soundararajan. Hindu on Campus documents that her caste trainings openly targets Hinduism and upper-caste Hindus. Tom Clark’s legal analysis, pg. 4.
100 July 5th, 2023 Dubious Testimony Attorney Tarina Mand, from SABA San Diego, and witness for SB403, mis-characterizes the Cisco’s case judge’s order denying the caste survey and all the caste discrimination testimonies, stating, “courts will be reluctant to admit evidence based on caste, even if it’s relevant to the case”. The judge denied the submitted data (see Timeline: Feb 11th, 2021) because they were not worthy of judicial notice. The data was (self-acknowledged as) unscientific, and testimonies were anonymous and not corroboratable. Tarina Mand’s testimony, time stamp 1:32:10.
101 July 5th, 2023 Misleading Testimony Ex-Google Employee,and witness for SB403, Tanuja Gupta states that an “expert speaker’s talk about Dalit Civil Rights” was cancelled at google, and blames it on a “hecklers veto.” But she hides the fact that the proposed speaker, was the openly Hinduphobic, Thenmozhi Soundarajan, who even calls “upper-caste Hindus as Nazis.” Tanuja Gupta’s testimony, timestamp 1:29:17.
102 July 5th, 2023 Evasive Behavior Equality labs founder Thenmozhi Soundarajan, will not answer questions on whether they are a non-profit, or her sources of funding, claiming that answering these basic questions is akin to being bullied. Thenmozhi Soundarajan refuses to answer a Diya TV reporter.
103 July 13th, 2023 Constitutional violation, Conspiracy In 2021, the Bochasanwasi Akshar Purushottam Swaminarayan Sanstha (BAPS) Shri Swaminarayan Mandir in Robbinsville in New Jersey were accused of using forced labor along with claims of labor and immigration law violations to build a Hindu temple. The workers claimed that BAPS had reasonably made them believe that if they tried to leave their work and the temple compound, they would suffer physical restraint and serious harm [Collective and Class Action Complaint, pg. 4, ln 3-5]. Shockingly, High Court Advocate Aaditya SB Soni of the Rajasthan State in India, in their press release, stated that over a dozen workers who were part of the lawsuit against BAPS have withdrawn their names from the lawsuit and were threatened to be part of a deep-rooted conspiracy to stall the construction of the grand Hindu Temple. Press release by Bharatiya Majdoor Sangh and Patthar Gadhai Sangh,  [pg. 1 ln. 6-8].
104 July 16th, 2023   Sundar Iyer made his first public appearance in public at Caste Conference (CasteCon) which was held in Silicon Valley to dispel misconceptions relating to the concept of caste. Exonerated tech exec Sundar Iyer makes his first public comment at ‘CasteCon’.
105 July 17th, 2023   Cisco refuses to settle with CRD in their mediation meetings after the CRD withdrew its case. Case Management Statement filed in the Superior Court of California, County of Santa Clara.
106 September 21st, 2023 Civil Rights Violations Hindu American Foundation files first amended complaint against Kevin Kish, CRD. Sundar Iyer and Ramana Kompella along with others are the Plaintiffs who have suffered injury due to CRD’s unconstitutional acts. First Amended Complaint filed in Federal Court, Eastern District of California.
107 October 3rd, 2023   Plaintiff CRD’s (DFEH) Supplemental Opposition to Defendant Cisco Systems Demurrer Opposition Statement filed in the Superior Court of California, County of Santa Clara.
108 October 7th, 2023   Governor Gavin Newsom of California vetoes caste bill SB-403, calling it “unnecessary” because existing statutes already prohibit discrimination based on several categories, including sex, race, religion, disability, ancestry, etc. State law specifies these statutes should be “liberally construed.” Veto Letter from Governor Newsom.
109 October 10th, 2023   Voluntary Dismissal of Claims by 12 Plaintiffs in the BAPS lawsuit stating that they no longer want to pursue the lawsuit.


Order from Federal Court, District of New Jersey.

110 October 27th, 2023   CRD’s opposition to the Hindu American Foundation’s Motion for Leave to Intervene Opposition To Intervention filed in the Superior Court of California, County of Santa Clara.
111 November 6th, 2023 Civil Rights Violations Hindu American Foundation’s Reply in support of Motion for Leave to Intervene Reply in support of Intervention filed in the Superior Court of California, County of Santa Clara.
112 December 6th, 2023 Frivolous Arguments CRD and John Doe’s motion to proceed by fictitious name is DENIED. Order by Judge of the Superior Court of California, County of Santa Clara.
113 December 21st, 2023 Civil Rights Violations CRD Forced to file Amended Complaint First Amended Complaint
114 January 23rd, 2024 Due Process, Equal Protection CISCO submits answer to CRD’s amended complaint and requests the Court to dismiss CRD’s case in its entirety with Prejudice. Answer by CISCO.
115 March 11th, 2024 Discovery and Trial Date CRD is forced to disclose that John Doe is Chetan Narsude. Fact Discovery to be completed by 3/26/2025. Expert Discovery to be completed by 5/26/2025. Jury Trial Date to be set in future. Case Management Statement filed  on 3/11/2024.
116 March 14th, 2024 Appeal Appeal filed in California State University (CSU) Caste Lawsuit. Appellant’s Opening Brief filed on 3/14/2024.
117 March 18th, 2024 Second Amended Complaint Second Amended Complaint Filed by CRD against Cisco Systems after Court orders CRD to remove definition of Caste as a Hindu strict social hierarchy. Second Amended Complaint filed by CRD on 3/18/2024.
118 March 21st, 2024 Amicus Brief Americans United for Separation of Church and State, a Civil Rights Organization files Amicus Brief in CSU Caste Lawsuit. Amicus Brief filed on 3/21/2024.
119 April 5th, 2024 Status Letter BAPS Plaintiffs’ counsel asked the government for an update on the status of the criminal
investigation and were informed that the government investigation is still ongoing, and that it still includes investigation into allegations of human trafficking-related (Chapter 77) offenses.
Because the investigation is ongoing, BAPS’ position is that the Trafficking Victims
Protection Act, 18 U.S.C. § 1595(b), requires that the stay—entered by the Court on the parties’ consent in November 2021—remain in effect pending the conclusion of the government investigation.
Status Letter filed on 4/5/2024.
120 May 15th, 2024 Motion to Compel Cisco Systems’ Motion to Compel – Court orders CRD to produce the documents it is relying upon along with a privilege log if CRD is withholding documents under privilege. Court also awards $2,000 in sanctions against CRD in favor of Cisco Systems. Court Order for Motion to Compel filed on 5/15/2024.
121 May 17th, 2024 Stipulation and Order Joint Stipulation and Proposed Order Extending CRD’s Deadline to File Demurrer and Motion to Strike. Stipulation and Order filed on 5/17/2024.
122 May 20th, 2024 Motion to Dismiss CRD files Motion to Dismiss against Hindu American Foundation’s (HAF) complaint in Federal Court. Motion to Dismiss filed by CRD on 5/20/2024.
123 May 22nd, 2024 Appeal Appeal filed in Seattle City Council (SCC) Caste Lawsuit. Appellant’s Opening Brief filed on 5/22/2024
124 May 29th, 2024 Amended Answer to Second Amended Complaint Cisco Systems files answer to CRD’s second amended complaint exposing John Doe aka Chetan Narsude. The answer highlights Narsude’s habit of resisting and delaying doing the work assigned to him, lack of responsiveness to
questions from his team, lack of availability during business hours and his sometimes abrasive style of communication, which created division in the team and made team members reluctant to
approach him with questions. Additionally, two of Narsude’s prior team members had complained about Narsude’s lack of leadership, poor management, and communication and stated that they did not want to work with Narsude as their lead.
Amended Answer filed by Cisco Systems on 5/29/2024