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Although it is tempting to describe the conduct of Tinder’s senior executives as “frat-like,” it was in fact much worse- representing the worst of the misogynist, alpha-male stereotype too often associated with technology startups. Wolfe repeatedly complained to CEO Rad, he ignored her complaints, dismissing her as “annoying” and “dramatic,” and threatened her job. Along with co-founders, Sean Rad, Christopher Gulczynski, Jonathan Badeen, and Joe Munoz, Wolfe had been part of a fledgling company working at the IAC-funded incubator, Hatch Labs. Mateen told her that it was a threat he would not tolerate. Wolfe’s friend, Kate Wilson, who accompanied her to the event. Mateen responded: “You’re a whore.” He accused her of being with a boy and insisted he knew all about what her “disgusting self had been up to.” He said this in front of Mr. He went on call her “a gold digger,” and “a disease” and “disgusting.” As Ms.

Wolfe to a barrage of horrendously sexist, racist, and otherwise inappropriate comments, emails and text messages, including describing one person as a “liberal lying desperate slut” and others as “middle age Muslim pigs” and referring, for example, to “fucking” the wife of a prominent blogger, and a text depicting IAC Chairman Barry Diller as a penis. Mateen called her a “whore” at a company event, and she offered to resign in consideration for modest severance and the vesting of her stock. As far back as May 2012, before there even was a Tinder, Wolfe was a key player on the team that produced the wildly successful mobile dating app. Mateen was unwilling to say “hello” to her, while he eagerly greeted Ms. Rad that she would leave peacefully if she could get a reasonable amount of severance and her vested equity.

FACTUAL BACKGROUND Whitney Wolfe has been a driving force of Tinder from the very beginning. Wolfe, beaten down by the abuse and fearing for her reputation if she was fired ostensibly for performance reasons, texted Mr.

They called the app “Matchbox.” In the July to August 2012 time period, while the Matchbox prototype was undergoing further design, the company, including CEO Sean Rad, continued to focus on Cardify. Gulczynksi, everyone in the group was impressed with Ms. Mateen that she would go to HR to file a formal complaint, Mr. Wolfe’s joint employer, completely abdicated any supervisory role over its Tinder employees. Rad thought little of IAC is evident in at least one obscene text he sent to Ms. Wolfe sought her advice as to what to do about the on-going harassment, going so far as to say that the abuse was unbearable: “[t]he shit he says when he talks makes me wanna kill myself he’s so low and nasty I might quit.” See texts between Ms.

That might have been the end of the road for the Matchbox app, but Ms. Wolfe’s vision, and they encouraged her to follow through with her college campus marketing plan to see if the product had any future. Rad told her that it was her job to “keep Justin calm.” If she couldn’t do that she would be fired. Wolfe in the summer of 2013, depicting IAC Chairman Barry Diller as a penis. Rad was dating Alexa Dell, the 20-year old daughter of an iconic technology figure.

Wolfe quickly saw its potential and began aggressively lobbying Mr. Wolfe argued that they should “put Cardify to bed” and really focus on Matchbox. Justin Mateen, who would later be hired as Tinder’s Chief Marketing Officer and go on to sexually harass Ms.

Rad to shift the focus of the group away from the Cardify app, and towards the app that would eventually become the Tinder app. She explained her marketing plan of taking the app to various colleges and increasing its user base through appealing to students. Wolfe, was not an employee or part of the group at this time and played no role in the meeting in which Ms. Wolfe refused, he called her a series of obscene names and threatened that if Ms.

She argued that the app was going to be a phenomenal success if marketed properly. Wolfe sold her marketing strategy to the remaining members of the co-founder team. She suggested “Tinder” because tinder helps to light a flame, which had obvious dating analogues. Wolfe didn’t “fix it” she would suffer consequences. Mateen’s behavior was so outrageous that an onlooker from an apartment above the street directly behind Tinder’s offices where the argument took place intervened urging him to stop.

Rad eventually agreed that she could pitch it to the team and see if they were interested. Wolfe presented her marketing plan to the other Cardify employees, Mr. At around this same time, it occurred to the group that the Matchbox name was potentially problematic in that it was similar to “match,” and IAC wholly owned the dating website/app, On September 14, 2012, the day of her flight to Southern Methodist University (SMU) to unveil the newly-named Tinder app, Ms. Rad who had several on-going projects with him, told her that Mr. Wolfe because she was “an alcoholic who lost control” (Ms. While CEO Rad did acknowledge that “Justin is nuts” when Ms. Mateen did not limit his abuse to his in-person, workplace encounters with Ms. He subjected her to a barrage of aggressive, angry texts in which Mr. Mateen’s anger, jealousy and control issues were so intense that they impacted Tinder business opportunities. Wolfe was contacted by the Creative Director of an influential fashion and lifestyle blog.

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