Noel, who is Trinidadian, holds a Bachelor of Science in Accounting, says that she started working at IPG in or around February 1993 and has endured racially indifferent behavior from several white supervisors and managers.

Noel claims that from March 15, 1994, through this day, Caucasian and Light Skinned Hispanic employees are treated more favorably than African-American or other Dark Skinned employees. She has witnessed several unqualified Caucasian and Light Skinned Hispanic employees offered opportunities or had positions created for them, receive larger salaries and greater benefits than more qualified African-American or other Dark Skinned employees, the lawsuit claims. Noel further claims that defendant IPG through its agents intentionally do not advertise job opportunities in its corporate headquarters to ensure that it remains a ‘Whites or Light Skinned Only’ location, such corporate job opportunities are filled through ‘Word of Mouth’ advertising.

“Whenever, African-American or other Dark Skinned employees complain about discrimination and related conduct in the workplace defendant IPG through its agents’ defendants’ MICHAEL I. ROTH (Caucasian Male); NICHOLAS JOSEPH CAMERA (Caucasian Male); MARJORIE MARY HOEY (Caucasian Female) and CAROLYN HARDING (African-American Female) as well as other members of the management ignore their complaints” says Noel.