He applied for four other positions within the company but was not hired for any of them. Although he had been involuntarily terminated, IBM marked him as having "resigned" in its human resources system, before sending him a letter congratulating him on his "retirement".
IBM told the US Equal Employment Opportunity Commission that his supervisor, Kim Overbay, chose him for termination because he had scored the lowest on her "secret stack ranking".
Langley claims he was tipped off in December 2016 by Overbay's superior, Andrew Brown, who told him in a private email that he needed to look for a new job — indicating the decision had already been made.
"IBM's primary method for taking out its older workers is surprisingly simple," the claim says. "A directive comes down to first and second line managers to reduce headcount. Using IBM's 'staff reduction methodology', first and second line managers generate secret ratings of employees eligible for reduction using predominantly subjective evaluation criteria.
"The employees are then ranked against one another and the lowest ranked employees are then selected for reduction.
"IBM managers sometimes reverse engineer their staff reduction worksheets by first selecting the employees they wish to terminate, and then creating ratings and rankings that purport to justify their selection decisions."
Langley devotes 22 pages of the 27-page court filing laying out examples of what he feels are evidence of IBM's alleged millennial bias, which began shortly after Ginni Rometty became chief executive in 2012.
The suit alleges Rometty wanted to focus heavily on cloud, analytics, mobile, security and social (CAMS) markets, and to "change the face of IBM" by recruiting "digitally native" millennials, which the company defined as the generation born after 1980.
"At a 2014 conference titled 'Reinvention in the Age of the Millennial', IBM expressly linked its success in CAMS to millennials, asserting that 'CAMS are driven by millennial traits'," the claim says.
It includes such exhibits as IBM ads and marketing materials featuring fresh-faced, purple haired programmers, Twitter messages using the hashtag #IBMillennial, and even a YouTube clip of a June 2017 interview with Mad Money's Jim Cramer in which IBM "ensured [Rometty] was surrounded by millennials busily working in the background".
In addition to efforts to "shed IBM's image 'as a company composed mainly of ageing white guys', and to substitute … 'rock star' millennials'", Langley accuses the company of denigrating older workers.
In 2015 it published a recruiting tool called "Myths, exaggerations and uncomfortable truths — The real story behind Millennials in the workplace", which alleged older workers were less technologically sophisticated because they were not "digital natives".
In another publication, IBM claimed "successor generations X and Y are generally much more innovative and receptive to technology than Baby Boomers" and that "age is catching up with Baby Boomers", referred to as "grey hairs" and "old heads".
It added that Baby Boomers were increasingly leaving work "due to retirement or disability" and that those still working often needed accommodations for "'wear and tear' disabilities like hearing and vision impairment [sic] that older people routinely develop".
Langley is seeking a reinstatement of employment in addition to lost wages and benefits, damages plus costs. The company has not yet filed a response.
IBM has been contacted for comment.
