Kleiner Perkins Caufield & Byers has filed a response to partner Ellen Pao’s allegations of gender discrimination and boy howdy, they did not hold back. We’ve obtained a copy, and here’s the meat and potatoes:
“KPCB generally denies each and every material allegation of the Complaint and further denies that Plaintiff has been damaged in the manner alleged, or in any manner or amount.”
The firm also “vigorously denies” that it discriminated or retaliated against Ms. Pao, as well as claiming that Ms. Pao never reported anything prior to 2011, and they also deny that she complained in 2007.
The response goes into great detail, refuting many of Ms. Pao’s accusations point-by-point:
- When she did complain in late 2011/early 2012, Ms. Pao was already represented by a lawyer, the filing claims.
- KP retained an outside investigator, who interviewed 17 partners, including every then-current KPCB female partner. The independent investigator concluded that her discrimination and retaliation complaints were without merit.
- KPCB denies that Raymond Lane pressured Ms. Pao to marry Mr. Nazre.
- She told Mr. Lane that she was putting the relationship with Mr. Nazre behind her, says the filing.
- That was in late 2011/early 2012, and that was the last any of the senior partners claim to have heard of the incident.
- In regards to the racy book she originally claimed to have received from Mr. Komisar, the response claims–well, it’s worth quoting in full: “That book [which the response identifies as The Book of Longing] was reviewed by the New York Times as ‘profound’ and having ‘exceptional range.’” The document also claims it was purchased as a gift for Ms. Pao by Mr. Komisar’s wife, and that Ms. Pao “never returned or objected to the gift in the many years after receiving it.
Regarding her performance reviews:
- In her 2009 self evaluation, she singled out the help she’d received from Komisar and other partners, saying that they are “supportive mentors and advisors.” She also “specifically requested Komisar review her performance after the incidents she alleges as harassment,” according to the filing.
- Initially, according to the filing, her reviews were encouraging: “Plaintiff’s 2009 review encouraged Plaintiff to speak up more effectively and influentially, step out more in a leading role, present more new investment ideas, and take more risks by incubating a high potential venture and owning it–hardly retaliatory input.” But it also ”encouraged her to focus on her interpersonal and ‘EQ’ skills to more effectively direct and motivate teams.” Then, in 2010, her review “advised Plaintiff that she was too ‘territorial’, that others did not ‘trust her motivations’ and that she had a ‘sense of entitlement rather than earning her position via contribution, expertise, and making her fellow partners successful.’”
Regarding the party Ms. Pao alleges she was not invited to, lest she kill the buzz:
- KPCB denies that Ms. Pao was ever excluded from any company activities based on her gender.
- The dinner Ms. Pao alleges she was not invited to because she was a woman did in fact have female partners in attendance.
- KPCB also denies that it “excluded women from two dinners in San Francisco in 2011 or that any KPCB event was marred or motivated by gender animus or discrimination.”
The also firm asserts that Ms. Pao was contractually obligated to seek third-party arbitration, and that by lodging a public suit, she has breached her contract. KPCB also claims that Ms. Pao was failed to competently perform the duties of her job.
KPCB is requesting “the Complaint be dismissed with prejudice and that Plaintiff take nothing,” “That judgment be entered in favor of KPCB on all claims; That KPCB be awarded its attorneys’ fees and costs of suit.”
Besides the answer to Ms. Pao’s complaint, documents filed include a motion to compel arbitration and a motion “to seal records lodged with the court filed by the defendant Kleiner Perkins.” There’s a hearing set for both issues on July 10.
Today was the deadline for KPCB to file a response, but they could have responded with a request for an extension. Instead, they’ve chosen to answer Ms. Pao’s allegations. Until now, the storied VC firm had been largely silent, except for a strongly worded (though largely detail-free) statement from John Doerr, which called Ms. Pao’s allegations false. Now we have a lot more details.
As of last week, Ms. Pao was still working at Kleiner Perkins.
Here’s the full document: