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All Plaintiffs in the lawsuit must share these characteristics:
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Have been laid off from a position in which the plaintiff wrote some computer program instructions (code) OR the position supported others who wrote code (e.g. DB admin, network admin, secretary, janitor).
- Does not include analysts who wrote no code, or managers who wrote no code.
- Does not include user technical support personnel who wrote no code.
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The work of the plaintiff was tranferred to workers in a nation other than the U.S.
- Does not include work that was transferred to a worker in the U.S on a H1B visa or a L-1 visa.
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At least 2 other workers from the same employer were laid off from positions and who also fulfill the two above characteristics.
- The other two workers need not be plaintiffs on this lawsuit.
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