Lawyers for Kleiner Perkins have filed a seven-page response to the charges laid against the venture-capital firm by Ellen Pao, a partner who claimed she’d suffered gender discrimination and retaliation by another partner, Ajit Nazre, with whom she had a sexual affair.
The complaint denies substantially all of her charges.
The firm is also claiming a host of affirmative defenses—which are ways of asserting that even if Pao made her case on the substantive claims, the lawsuit isn’t valid.
Here are the key points:
- “KPCB generally denies each and every material allegation of the Complaint.” That fits with the strongly worded response of Kleiner’s lead partner, John Doerr, who called Pao’s allegations “false.”
- Kleiner characterised Nazre and Pao’s relationship as “consensual.” (Pao said Nazre, who had been at the firm longer than her, had pressured her to have sex.)
- Kleiner admitted that one of its partners, Randy Komisar, gave Pao a copy of The Book of Longing by Leonard Cohen, but said that Komisar’s wife had purchased it for Pao. According to Kleiner’s response, Pao never returned the book—and didn’t mention it in Kleiner’s internal investigation into her claims.
- Kleiner denied that partners had held men-only dinners in San Francisco, and said one specific dinner that Pao’s complaint referred to included both men and women.
What the response doesn’t address:
- Did Nazre retaliate against Pao after the end of their sexual relationship?
- Did Nazre and Komisar interfere with Pao’s relationship with a Kleiner portfolio company, RPX? (Pao worked on the RPX deal, according to her official Kleiner bio, but Komisar took the board seat.)
- Why did Nazre leave the firm after the investigation?
- Were other women treated unlawfully at Kleiner, and if so, by whom?
Here’s the full document, fresh from the courthouse: