Crowdflower Response to Christopher Otey Complaint

document Cloud Labor

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LITTLER MENDELSON, P.C. 650 California Street 20th Floor San Francisco, CA 94108.2693 415.433.1940

ARTHUR M. EIDELHOCH, Bar No. 168096 aeidelhoch@littler.com GALEN M. LICHTENSTEIN, Bar No. 251274 glichtenstein@littler.com LITTLER MENDELSON, P.C. 650 California Street 20th Floor San Francisco, California 94108.2693 Telephone: 415.433.1940 Facsimile: 415.399.8490 JACQUELINE E. KALK (admission pro hac vice pending) jkalk@littler.com LITTLER MENDELSON, P.C. 80 South 8th Street, Suite 1300 Minneapolis, MN 55402-2136 Telephone: 612.313.7645 Facsimile: 612.677.3139 Attorneys for Defendants CROWDFLOWER, INC., LUKAS BIEWALD AND CHRIS VAN PELT UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION CHRISTOPHER OTEY, on behalf of himself and all others similarly situated, Plaintiff, v. DEFENDANTS, INC., LUKAS BIEWALD and CHRIS VAN PELT, Defendants. Case No. 4:12-cv-05524-CRB DEFENDANTS’ ANSWER AND DEFENSES TO COMPLAINT

DEFENDANTS’ ANSWER AND DEFENSES TO COMPLAINT

Case No. 4:12-cv-05524-CRB

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In response to Plaintiff Christopher Otey’s (“Plaintiff”) Complaint, Defendants CrowdFlower, Inc. (“CrowdFlower”), Lukas Biewald (“Biewald”) and Chris Van Pelt (“Van Pelt”) (collectively “Defendants”), through their undersigned counsel, hereby answer as follows: 1. Answering Paragraph 1 of the Complaint, Defendants deny that the Fair Labor

Standards Act (“FLSA”) can be properly applied to Plaintiff or any individuals that choose or chose to perform micro-tasks made available on the internet, and therefore Defendants deny all of the allegations contained in Paragraph 1 of the Complaint, except that Defendants admit that this action is brought as a collective action under the FLSA and that CrowdFlower describes itself as providing the World’s Largest Workforce. Further answering, Defendants deny that collective action treatment is warranted or appropriate in this matter. INTRODUCTION 2. Answering Paragraph 2 of the Complaint, Defendants admit that the United States

includes all 50 states, all territories, and the District of Columbia. The remainder of the allegations contained in Paragraph 2 of the Complaint merely state conclusions of law to which no response is required. To the extent a response is deemed necessary or appropriate, Defendants admit that Plaintiff attempts to state claims under the cited statute, but deny that Plaintiff is entitled to any of the requested relief and deny that collective action treatment is appropriate or warranted in this matter. 3. Answering Paragraph 3 of the Complaint, Defendants admit that CrowdFlower is an

internet based technology company that was established in late 2007 and that it describes itself as providing the World’s Largest Workforce. Defendants deny that the FLSA is applicable to Plaintiff and therefore deny all of the remaining allegations contained in Paragraph 3 of the Complaint. 4. Answering Paragraph 4 of the Complaint, Defendants deny all of the allegations

contained therein. PARTIES 5. Answering Paragraph 5 of the Complaint, Defendants are without information or

knowledge sufficient to form a belief as to the truth or falsity of the allegations regarding Plaintiff’s

DEFENDANTS’ ANSWER AND DEFENSES TO COMPLAINT

1.

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current residence and, therefore, deny those allegations. Defendants deny the remaining allegations of Paragraph 5 of the Complaint. 6. Answering Paragraph 6 of the Complaint, Defendants admit the allegations contained

therein. Further answering, Defendants deny that Plaintiff can properly represent the putative class and deny that Plaintiff is entitled to any relief under the FLSA. 7. Answering Paragraph 7 of the Complaint, Defendants deny that CrowdFlower Defendants admit the remaining

employed Plaintiff or any members of the putative class. allegations contained in Paragraph 7 of the Complaint. 8. therein. 9. therein. 10.

Answering Paragraph 8 of the Complaint, Defendants admit the allegations contained

Answering Paragraph 9 of the Complaint, Defendants admit the allegations contained

Answering Paragraph 10 of the Complaint, Defendants admit the allegations

contained therein. 11. Answering Paragraph 11 of the Complaint, Defendants deny all of the allegations

contained therein. JURISDICTION AND VENUE 12. Answering Paragraph 12 of the Complaint, Defendants deny that any alleged events

or omissions occurred that would give rise to a claim under the FLSA and deny that this matter is suitable for certification as a collective action pursuant to 29 U.S.C. § 216(b). Further answering, Defendants admit that the Court has subject matter jurisdiction over claims brought under the FLSA’s wage and hour provisions. 13. Answering Paragraph 13 of the Complaint, Defendants admit that venue is proper in

the United States District Court for the Northern District of California and that Plaintiff is bound by the referenced forum selection clause. Defendants deny the remaining allegations of Paragraph 13 of the Complaint.

DEFENDANTS’ ANSWER AND DEFENSES TO COMPLAINT

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FACTUAL ALLEGATIONS CrowdFlower’s Business Model 14. Answering Paragraph 14 of the Complaint, Defendants admit that CrowdFlower

describes itself as providing the World’s Largest Workforce and that its website address is www.CrowdFlower.com. Defendants deny the remaining allegations contained in Paragraph 14 of the Complaint. 15. Answering Paragraph 15 of the Complaint, Defendants admit that the identified

statement has been on CrowdFlower’s website. Defendants further state that the quoted language is taken out of context and that the webpage speaks for itself. 16. Answering Paragraph 16 of the Complaint, Defendants admit that CrowdFlower

maintains a webpage which can be interpreted as dividing the CrowdFlower community into those that provide work and contributors that may be interested in performing tasks. Defendants deny the implicit allegation that contributors may identify or perform any work through CrowdFlower’s webpage. Defendants further state that any document or webpage quoted or paraphrased speaks for itself. 17. Answering Paragraph 17 of the Complaint, Defendants deny all of the allegations

contained therein. 18. Answering Paragraph 18 of the Complaint, Defendants deny all of the allegations

contained therein. 19. Answering Paragraph 19 of the Complaint, Defendants admit that Mr. Biewald was

interviewed by Sramana Mitra in the fall of 2011. Defendants deny that the quoted language is a complete discussion of that interview and therefore deny all of the remaining allegations contained in Paragraph 19 of the Complaint. Defendants further state that the quoted language is either inaccurate or taken out of context and that any document or webpage quoted or paraphrased speaks for itself.

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Skills Required 20. Answering Paragraph 20 of the Complaint, Defendants deny all of the allegations

contained therein. Defendants further state that the referenced statement is either inaccurate or taken out of context and that any document, webpage, or video quoted or paraphrased speaks for itself. 21. Answering Paragraph 21 of the Complaint, Defendants deny all of allegations

contained therein. Defendants further state that the referenced statement is either inaccurate or taken out of context and that any document, webpage, or video quoted or paraphrased speaks for itself. 22. Answering Paragraph 22 of the Complaint, Defendants deny all of the allegations

contained therein. 23. Answering Paragraph 23 of the Complaint, Defendants deny all of the allegations

contained therein. 24. Answering Paragraph 24 of the Complaint, Defendants admit that the Contributor Further answering, Defendants state that the

Channel Handbook includes the quoted section.

referenced statement is not a complete statement of that document and that the document speaks for itself. 25. Answering Paragraph 25 of the Complaint, Defendants deny all of the allegations

contained therein. 26. Answering Paragraph 26 of the Complaint, Defendants deny all of the allegations

contained therein. 27. Answering Paragraph 27 of the Complaint, Defendants deny all of the allegations

contained therein. 28. Answering Paragraph 28 of the Complaint, Defendants deny all of the allegations

contained therein. 29. Answering Paragraph 29 of the Complaint, Defendants admit that CrowdFlower’s

software system tracks task completion in a variety of ways. CrowdFlower denies that it tracks specific workers and therefore denies all of the allegations contained in Paragraph 29 of the Complaint.

DEFENDANTS’ ANSWER AND DEFENSES TO COMPLAINT

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30.

Answering Paragraph 30 of the Complaint, Defendants deny all of the allegations

contained therein. 31. Answering Paragraph 31 of the Complaint, Defendants deny all of the allegations

contained therein. 32. Answering Paragraph 32 of the Complaint, Defendants deny all of the allegations

contained therein. CrowdFlower’s Wage Rates 33. Answering Paragraph 33 of the Complaint, Defendants deny that the FLSA is

applicable and, therefore, deny all of the allegations contained in Paragraph 33 of the Complaint. 34. Answering Paragraph 34 of the Complaint, Defendants deny all of the allegations

contained therein. Defendants further state that the referenced statement attributed to Mr. Biewald is either inaccurate or taken out of context and that any webpage, or video quoted or paraphrased speaks for itself. 35. Answering Paragraph 35 of the Complaint, Defendants are without information or

knowledge sufficient to form a belief as to the truth of what Plaintiff does or does not believe and, therefore, deny all of the allegations contained in Paragraph 35 of the Complaint. 36. Answering Paragraph 36 of the Complaint, Defendants deny all of the allegations

contained therein. 37. Answering Paragraph 37 of the Complaint, Defendants deny that the minimum wage

laws are applicable and, therefore, deny all of the allegations of Paragraph 37 of the Complaint. Defendants further state that the referenced statement is either inaccurate or taken out of context and that any document, webpage, or video quoted or paraphrased speaks for itself. Willfulness 38. Answering Paragraph 38 of the Complaint, Defendants deny all of the allegations

contained therein. 39. Answering Paragraph 39 of the Complaint, Defendants deny all of the allegations

contained therein.

DEFENDANTS’ ANSWER AND DEFENSES TO COMPLAINT

5.

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40.

Answering Paragraph 40 of the Complaint, Defendants admit that Mr. Biewald made

the quoted comment, but further state that the referenced statement is taken out of context and that any document, webpage, or video quoted or paraphrased speaks for itself. 41. Answering Paragraph 41 of the Complaint, Defendants admit that Mr. Biewald made

the quoted comment, but further state that the referenced statement is taken out of context and that any document, webpage, or video quoted or paraphrased speaks for itself. 42. Answering Paragraph 42 of the Complaint, Defendants admit that Mr. Biewald made

the quoted comment, but further state that the referenced statement is taken out of context and that any document, webpage, or video quoted or paraphrased speaks for itself. 43. Answering Paragraph 43 of the Complaint, Defendants deny all of the allegations

contained therein. CrowdFlower’s Size and Proliferation in the Unites States 44. Answering Paragraph 44 of the Complaint, Defendants deny all of the allegations

contained therein. 45. Answering Paragraph 45 of the Complaint, Defendants admit that Mr. Biewald made

the quoted comment, but further state that the referenced statement is taken out of context and that any document, webpage, or video cited or paraphrased speaks for itself. 46. Answering Paragraph 46 of the Complaint, Defendants admit that Mr. Biewald made

the quoted comment, but further state that the referenced statement is taken out of context and that any document, webpage or video cited speaks for itself. 47. Answering Paragraph 47 of the Complaint, Defendants admit that Mr. Biewald made

the quoted comment, but further state that the referenced statement is taken out of context and that any document, webpage or video cited speaks for itself. 48. Answering Paragraph 48 of the Complaint, Defendants admit that Mr. Biewald made

the quoted comment, but further state that the referenced statement is taken out of context and that any document, webpage or video cited speaks for itself.

DEFENDANTS’ ANSWER AND DEFENSES TO COMPLAINT

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49.

Answering Paragraph 49 of the Complaint, Defendants deny all of the allegations

contained therein. Collective Action Allegations 50. Answering Paragraph 50 of the Complaint, Defendants admit that Plaintiff purports to

bring Count I as an “opt-in” collective action on behalf of allegedly similarly situated persons pursuant to Section 216(b) of the FLSA. Defendants deny that they were Plaintiff’s employer under the FLSA, that Plaintiff was similarly situated to any person or persons he purports to represent, that any alleged events or omissions occurred that would give rise to a claim under the FLSA, and/or that that this matter is suitable for certification as a collective action pursuant to 29 U.S.C. § 216(b). 51. Answering Paragraph 51 of the Complaint, Defendants deny all of the allegations

contained therein. 52. Answering Paragraph 52 of the Complaint, Defendants deny all of the allegations

contained therein. 53. Answering Paragraph 53 of the Complaint, Defendants admit that Plaintiff purports to

bring this lawsuit on behalf of himself and others who are allegedly similarly situated to him seeking relief under the FLSA. Defendants deny all of the remaining allegations contained in Paragraph 53 of the Complaint. VIOLATION OF THE FAIR LABOR STANDARDS ACT OF 1938 54. Answering Paragraph 54 of the Complaint, Defendants incorporate and adopt their

responses to Paragraphs 1 through 53 of the Complaint as if fully set forth herein. 55. Answering Paragraph 55 of the Complaint, Defendants deny all of the allegations

contained therein. 56. Answering Paragraph 56 of the Complaint, Defendants state that the Paragraph

merely states a legal conclusion to which no answer is required. To the extent that an answer is deemed necessary, Defendants deny that the FLSA is applicable to Plaintiff and therefore deny all of the allegations contained in Paragraph 56 of the Complaint.

DEFENDANTS’ ANSWER AND DEFENSES TO COMPLAINT

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57.

Answering Paragraph 57 of the Complaint, Defendants deny all of the allegations

contained therein as they pertain to Plaintiff and those he purports to represent. 58. Answering Paragraph 58 of the Complaint, Defendants deny all of the allegations

contained therein as they pertain to Plaintiff and those he purports to represent. 59. Answering Paragraph 59 of the Complaint, Defendants deny all of the allegations

contained therein. 60. Answering Paragraph 60 of the Complaint, Defendants deny all of the allegations

contained therein. 61. Answering Paragraph 61 of the Complaint, Defendants deny that the FLSA is

applicable and therefore deny all of the allegations contained in Paragraph 61 of the Complaint. 62. Answering Paragraph 62 of the Complaint, Defendants state that the Paragraph

merely states a legal conclusion to which no answer is required. To the extent that an answer is deemed necessary, Defendants deny that the FLSA is applicable to Plaintiff and therefore deny all of the allegations contained in Paragraph 62 of the Complaint. 63. Answering Paragraph 63 of the Complaint, Defendants deny all of the allegations

contained therein. 64. Answering Paragraph 64 of the Complaint, Defendants deny all of the allegations

contained therein. 65. Answering Paragraph 65 of the Complaint, Defendants deny all of the allegations

contained therein. 66. Answering Paragraph 66 of the Complaint, Defendants deny all of the allegations

contained therein. 67. Answering Paragraph 67 of the Complaint, Defendants deny all of the allegations

contained therein. 68. Answering Paragraph 68 of the Complaint, Defendants deny all of the allegations

contained therein.

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69.

Answering Paragraph 69 of the Complaint, Defendants deny all of the allegations

contained therein. GENERAL DENIAL Except to the extent expressly admitted herein, Defendants deny each and every allegation, matter, statement, and thing contained in the Complaint. FIRST DEFENSE The Complaint fails to state a claim upon which relief can be granted. SECOND DEFENSE Defendants did not employ Plaintiff or any potential members of the putative class or any subclass that Plaintiff purports to represent. THIRD DEFENSE Plaintiff’s claims are barred in whole or in part by the applicable statutes of limitation, including, without limitation, 29 U.S.C. § 255. This defense may also apply to the purported claims of some or all of the potential members of the putative class or any subclass that Plaintiff purports to represent. FOURTH DEFENSE Plaintiff’s purported claims are barred in whole or in part by the doctrine of judicial estoppel. This defense may also apply to the purported claims of some or all of the potential members of the putative class or any subclass that Plaintiff purports to represent. FIFTH DEFENSE The potential members of the putative class or any subclass Plaintiff purports to represent cannot proceed collectively under 29 U.S.C. § 216(b), because they are not similarly situated. SIXTH DEFENSE Assuming arguendo that Plaintiff is deemed an employee under the FLSA, his claims lack merit because Plaintiff was paid for all of the time he actually worked, at a rate equal to or greater than the hourly minimum wage required under the FLSA.

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SEVENTH DEFENSE Plaintiff’s purported claims are barred in whole or in part by Plaintiff’s contract(s) with CrowdFlower or relevant third parties. EIGHTH DEFENSE Plaintiff’s purported claims are barred because he lacks standing to assert the claims as he was never an employee of Defendants. NINTH DEFENSE Plaintiff’s claims against defendants Biewald and Van Pelt, to the extent Plaintiff is deemed an employee of CrowdFlower under the FLSA, cannot be maintained as they are not subject to individual liability. TENTH DEFENSE Plaintiff’s claims and the claims of “similarly situated individuals” are barred in whole or in part by the provisions of Section 10 of the Portal-to-Portal Act, 29 U.S.C. § 259, because actions taken in connection with Plaintiff’s compensation and the compensation of the alleged putative class or any subclasses were taken in good faith. ELEVENTH DEFENSE Plaintiff’s claims and the claims of “other persons similarly situated” are barred in whole or in part by any exemptions, exclusions, exceptions, or credits provided in Section 7 of the Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 207. TWELFTH DEFENSE To the extent Plaintiff is entitled to recover additional compensation, Defendants have not willfully or intentionally failed to pay, liquidated damages should not be awarded and only a twoyear statute of limitations should apply. THIRTEENTH DEFENSE Plaintiff’s claims and the claims of the putative class are barred in whole or in part by the provisions of Section 11 of the Portal-to-Portal Act, 29 U.S.C. § 260, because any acts or omissions

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giving rise to this action were done in good faith and with reasonable grounds for believing that the actions or omissions were not a violation of the FLSA. FOURTEENTH DEFENSE Plaintiff cannot establish or satisfy the requirements for class certification pursuant to 29 U.S.C. § 216(b) of the FLSA, and therefore, the class certification allegations of the Complaint must be stricken and dismissed. FIFTEENTH DEFENSE Plaintiff’s claims and the claims of the putative class are barred in whole or in part by the provisions of Section 4 of the Portal-to-Portal Act, 29 U.S.C. § 254, as to all hours during which they were engaged in activities that were preliminary or post-preliminary to their principal activities. SIXTEENTH DEFENSE Any claim for additional compensation by Plaintiff and the putative class must be reduced by compensation already paid to them for periods not compensable under the FLSA. See, e.g., 29 C.F.R. § 785.19. SEVENTEENTH DEFENSE Some work allegedly performed by Plaintiff and the putative class was completely voluntary in nature and without CrowdFlower’s knowledge or authorization, was contrary to express instructions, was not required by CrowdFlower as a term or condition of employment, and does not constitute compensable working time under the FLSA as a matter of law pursuant to 29 C.F.R. § 785.27, et seq. EIGHTEENTH DEFENSE Any time spent by Plaintiff or the putative class was de minimis. NINETEENTH DEFENSE Defendants received no benefit or value from some of the services performed by Plaintiff and the putative class.

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TWENTIETH DEFENSE Upon information and belief, some work allegedly performed by Plaintiff and any putative class member constituted “downtime” or other non-compensable work hours that was not subject to compensation under the provisions of the FLSA. TWENTY-FIRST DEFENSE Plaintiff and the putative class are not entitled to equitable relief as they have an adequate remedy at law. TWENTY-SECOND DEFENSE Defendants reserve the right to assert additional defenses or claims that may become known through the course of discovery. WHEREFORE, Defendants pray that the Court: (a) (b) (c) action; and, (d) award Defendants any such other and further relief it deems just and proper. dismiss the Complaint in its entirety, and with prejudice; enter judgment in favor of Defendants; award Defendants their costs and reasonable attorneys’ fees incurred in defending this

Dated: December 20, 2012 /s/ Galen M. Lichtenstein ARTHUR M. EIDELHOCH GALEN M. LICHTENSTEIN LITTLER MENDELSON, P.C. Attorneys for Defendants CROWDFLOWER, INC., LUKAS BIEWALD AND CHRIS VAN PELT
Firmwide:117002054.1 073860.1001

DEFENDANTS’ ANSWER AND DEFENSES TO COMPLAINT

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No. 4:12-cv-05524-CRB

Description Crowdflower's response to a complaint brought in federal court by a former worker. See our full coverage in the source link below:

http://www.crowdsourcing.org/editorial/the-lawsuit-that-could-help-undo-or-cement-crowdsourcing-in-the-us/22968/

Tags: Christopher Otey, Cloud Labor, courts, Crowdflower, Crowdsourcing, FLSA, Lawsuit

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