On May 9, 2025, Google agreed to pay $50 million to settle a class-action lawsuit brought by over 4,000 Black employees who alleged the company engaged in systemic racial discrimination. The lawsuit was originally filed on March 2022 by former Google recruiter April Curley with the Civil Rights Department of the State of California. Curley claimed that Black workers were routinely assigned to lower positions, underpaid, and denied advancement opportunities, often under vague, subjective standards like not being “Googley” enough.

This historic case is more than a tech industry headline. It is a critical warning to federal contractors.

Although Google denies wrongdoing, the company has now committed to a series of non-monetary reforms: reviewing racial pay disparities, increasing transparency in promotions and salary ranges, and halting forced arbitration for employment disputes. These steps closely mirror what federal contractors are expected to do annually: conduct self-assessments to ensure fair and unbiased employment practices.

Yet many federal contractors have paused or reduced their anti-discrimination evaluations following the revocation of Executive Order 11246. This is a dangerous misstep. Executive Order 14173, which replaces it, is ushering in a new certification requirement, one that will likely require contractors to attest, under penalty of perjury, that their workplace is free of unlawful discrimination. Any misrepresentation could trigger False Claims Act (FCA) liability, including treble damages.

Furthermore, state civil rights agencies are increasingly filling federal enforcement gaps, pursuing claims against employers based on discriminatory hiring, pay, and promotional practices. The Google case underscores how internal cultural issues and unchecked bias can lead to massive financial and reputational damage—even without a federal audit.

Federal contractors should view this moment as a turning point. Now is the time to:

  • Conduct a comprehensive, documented evaluation of hiring, pay, promotions, and terminations.
  • Identify and remedy potential patterns of systemic discrimination.
  • Preserve defensible records to support future EO 14173 certifications.
  • Train managers and recruiters to avoid subjective decision-making based on cultural fit.

Failure to act could invite lawsuits, loss of contracts, or worse, exposure under the False Claims Act. Google’s $50 million lesson should not be learned the hard way by government contractors.


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