JURISDICTION

This is a Title IX and Title VI complaint against multiple Johns Hopkins University, University of
Pennsylvania, and Carnegie Mellon University. As they all receive funds from the Federal Department of
Education, there is no extended discussion needed to establish OCR’s jurisdiction in this matter.

SUMMARY
The Universities are promoting and accepting funds for a scholarship program that discriminates on the
basis of sex. They are responsible for nominations, and they are responsible for adhering to sex and racial
quotas in those nominations.

ARGUMENTS
Argument 1. Google has scholarship that discriminates based on sex and race.

Google runs a scholarship for PhD fellowships that explicitly discriminates based on sex and race1. In the
US, this includes full tuition and fees, a google research mentor, and up to three years of fellowship. The
page also states under “How many students may each university nominate” that there are quotas:

Universities in the United States and Canada may nominate up to four eligible students
from Computer Science or related fields. If more than two are nominated, then in order
to increase opportunities for students who are underrepresented in the field of
computing, additional nominees must self-identify as a woman, Black/African American,
American Indian/Alaskan Native, Hispanic/Latinx, Native Hawaiian/Pacific Islander and/or
person with a disability. In other words, if a university chooses to nominate more than 2
students, then the 3rd and 4th student nomination should self-identify with the
underrepresented group mentioned above.

A University nominating students may only nominate two students who are not part of the desired sex or
race.

Argument 2. The University nominates students.

Per Argument 1, the University is responsible for nominating students. The University is also responsible
for adhering to the quotas of sex and race that are nominated.

Argument 3. The University has explicitly advertised and used University resources for this scholarship.

Per Argument 2, the University is responsible for nominations and quotas. Johns Hopkins 2, University of
Pennsylvania3, and Carnegie Mellon University4 have mentioned the scholarship on the University
webpage. The list of schools awarded the fellowship is located on Google’s page5. All schools have been
involved with nomination and adhering to quotas in order to receive the fellowship.

1
https://web.archive.org/web/20200403103423/https://research.google/outreach/faq/?category=phd
2
https://provost.jhu.edu/wp-content/uploads/2020/08/GooglePhDFellowship2020.pdf
3
https://curf.upenn.edu/content/google-fellowship
4
https://www.cs.cmu.edu/~gradfellowships/
5
https://research.google/outreach/phd-fellowship/recipients/
ALLEGATIONS
Allegation 1. The University is in violation of 34 CFR 106.37.

In general, for running, advertising, and promoting the scholarship.

Allegation 2. The University is in violation of 34 CFR 106.37(a)(1).

By limiting eligibility for the scholarship.

Allegation 3. The University is in violation of 34 CFR 106.37(a)(2)

By assisting the organization in increasing the visibility of the scholarship via the publication of articles
and/or directly linking to the scholarship page.

Allegation 4. The University is in violation of 34 CFR 106.37(a)(3)

By applying the rule that one must be a specific sex to accept these scholarships.

Allegation 5. The University is in violation of 34 CFR 106.31(a)

By advertising an activity that explicitly discriminates on the basis of sex.

Allegation 6. The University is in violation of the legal analogues under Title VI that are race-based.

RESOLUTION
When Title IX was passed, the gender gap in education was smaller and closing. It is now larger and getting
increasingly worse every year. It is time that civil rights law, particularly Title IX, be seriously enforced for
men. The idea that only non-men need target support, or that diversity only matters when women are a
minority is counter-current to civil rights law. This University, by their actions, continues to perpetuate
those stereotypes.

I ask that:
1. the University immediately discontinue accepting these scholarships.
2. the University publicly admonish sexism and racism it has engaged in.
3. the University remove all references to the scholarships on it’s webpage, and social media.
4. the University conduct a comprehensive review of its scholarship programs for compliance.