Alphabet, Inc. (GOOG, GOOGL) shareholders have filed a lawsuit against the Company’s Board of Directors alleging the tech giant violated state and federal law regarding both issues of workplace sexual harassment and a serious data breach. The Plaintiffs, Northern California Pipe Trades Pension Plan and Teamsters Local 272 Labor Management Pension Fund, are current stockholders of the Company and are represented by Cohen Milstein Sellers & Toll PLLC and Berman Tabacco, as local counsel. The complaint was filed January 9 in Superior Court, San Mateo County, California.

This is the first time that shareholders are filing a derivative complaint—a complaint in which shareholders step into the shoes of the Company to enforce their right to bring about changes—on both these issues.

In the 62-page complaint, the shareholders seek redress from the injury and losses that they allege were sustained by Alphabet as a result of breaches of fiduciary duty and “culture of concealment” that led Defendants to pursue their own interests and participate or acquiesce in the cover-ups of a long-standing pattern of sexual harassment and discrimination by high-powered male executives. The complaint notes that Alphabet’s directors and officers have been dismissive in response to sex discrimination and sexual harassment issues.

“We are hoping this lawsuit will create greater value for Alphabet’s stockholders and will also ensure that the Company demonstrates a greater commitment to a safe and fair workplace,” said Julie Goldsmith Reiser, partner at Cohen Milstein who represents the shareholders.

The lawsuit also alleges Alphabet failed to disclose a data privacy breach that exposed the personal data of a half a million users of Google+, a social networking website operated by the Company. In particular, it notes that a group of U.S. Senators criticized management for a “culture of concealment and opacity set from the top of the Company.”

“As the complaint’s allegations make clear, Alphabet’s Directors’ derogation of their duties owed to the Company and its shareholders is unacceptable,” said Carol V. Gilden, a partner at Cohen Milstein who is also representing the shareholders. “They need to be held responsible for any harm they have caused and take steps to reform the Company’s governance and internal controls so this conduct does not reoccur.”

A full copy of the complaint filed is available here.

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