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Kleiner Perkins Files Answer to Sexual Discrimination Complaint

The venture capital firm denies that plaintiff Ellen Pao ever complained about unlawful harassment until late 2011.

More than a month after Ellen Pao accused the firm of sexual discrimination, Kleiner Perkins Caufield & Byers has responded.

Attorneys defending venture capital firm Kleiner Perkins filed a seven-page answer to Pao’s initial legal complaint with Superior Court in San Francisco. In the document, the firm vehemently denies Pao’s allegations of misconduct and says it is not guilty of any wrongdoing in handling the situation.

Specifically, Kleiner Perkins says Pao didn’t notify any supervisors or fellow employees that she was being subjected to sexual harassment until late 2011–at which point she had already retained counsel regarding the matter. When Kleiner Perkins did finally hear of the possible abuse, the firm hired an independent investigator to look into the claims, the answer says. According to the answer, this outside investigation found that Pao’s “discrimination and retaliation complaints were without merit.”

In her complaint filed in May, Pao said that she voiced complaints about being pressured into a sexual relationship with a fellow partner at the venture capital firm, but that she was told to keep quiet about the incident. After she ended the sexual relationship, her lawsuit says, her profit share was reduced and the firm tried to transfer her to China.

In the court filing, the firm says that Pao’s relationship with her peer was consensual.

Pao also accused senior partner Raymond Lane of pressuring her to marry the man who was sexually harassing her. The answer to the complaint denies this and also says Pao received performance reviews that encouraged her to be more proactive and take on more “thought leadership” within the firm.

The court filing also includes negative aspects of Pao’s various performance reviews. According to the excerpts included in the answer, Pao was consistently viewed as being too soft-spoken, and that at times, people questioned her motivations and thought she exhibited an unearned “sense of entitlement.”

Kleiner Perkins also says that Pao has breached her contractual agreements with the firm by not asserting the claims in an arbitration forum.

The full text of the Kleiner Perkins response can be found below.

Ellen Pao v Kleiner Perkins - June 13,2012

IMAGE: iStock
Last updated: Jun 14, 2012


John McDermott is a business and culture reporter whose work has appeared in the Chicago Tribune and Playboy and on He recently moved from Chicago to Brooklyn, New York, to work for

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