Williams v. Tata Consultancy Services CA2/8

INTRODUCTION

Defendant Tata Consultancy Services, LTD. (TCS) appeals from the trial court’s order denying its motion to compel arbitration of plaintiff Jessamyn Williams’s single cause of action under the Private Attorneys General Act of 2004 (PAGA) (Lab. Code,1 § 2698 et seq.). TCS argues the court erred in finding Williams did not assert an individual PAGA claim that must be arbitrated. We disagree and conclude Williams asserted only a nonindividual PAGA claim that falls outside the scope of the parties’ arbitration agreement. Accordingly, we affirm.

BACKGROUND

TCS is a multi-national corporation that provides technology and consulting services, and business solutions to companies throughout the world. TCS is headquartered in Mumbai, India, but it operates in over forty countries and has employees located throughout the world. One of TCS’s subsidiaries is Tata America International Corporation (“TAIC”), which is incorporated in New York and offers technology, consulting, and computer systems integration services across the United States. TCS and TAIC share human resource services, including those related to recruitment, onboarding, and personnel record maintenance. In January…