Internal documents allegedly labelled veteran staff 'dinobabies' and 'old heads'
Three workers who gave IBM a combined 95 years allege the tech giant fired them to make room for younger hires.
The complaint, filed September 20, 2026, in the US District Court for the Southern District of New York, alleges IBM terminated the three employees - aged 57, 58, and 59 - under the pretext of a company restructure while simultaneously planning to backfill their roles with younger workers.
Two were Client Success Managers who worked directly with large IBM customers deploying enterprise software. The third managed compliance, data security, and audit programs. Between them, they had 27, 32, and 36 years of service. None had ever received a performance improvement plan, a disciplinary warning, or a negative review. All three had been promoted multiple times, with bonuses and equity awards along the way.
Then, in September 2024, IBM told each of them their position was being eliminated.
Those explanations were false, the complaint alleges. The work all three had performed continued after they left - because it had to. The roles were critical. Two of the workers say their responsibilities were handed to younger employees. And in both of their teams, the complaint alleges, the three oldest members were also terminated - all with more than 25 years at IBM.
What makes this filing unusual is what the complaint describes as a "smoking-gun" Slack message. According to the filing, an IBM vice president accidentally copied one of the workers on internal communications that showed the company was not just cutting headcount but was actively interviewing and hiring younger employees to fill some of the very positions being eliminated.
Planning documents circulated at IBM's leadership level - dated less than a month after the terminations - allegedly went further, specifying that new hires would be a mix of 60% "Early Professionals" and 40% "Campus Hires," according to the filing.
The complaint frames these terminations as part of a pattern stretching back years. IBM's rolling layoffs - internally called "Resource Actions" - allegedly used opaque selection processes and coded corporate language to target older workers while shielding younger ones. The filing cites internal terms such as "seniority mix," "skills remix," "next generation," and "revitalization hiring" as examples of language it says gave executives cover to discuss age-based workforce changes.
Then there are the publications. The complaint cites IBM materials that allegedly characterised older employees as less trusting, less collaborative, less committed, and less likely to understand the company's strategy than their younger colleagues. A 2018 ProPublica investigation, referenced in the filing, reported that an IBM consulting publication called older workers "gray hairs" and "old heads." And in 2022, the New York Times reported that top IBM executives had used the term "dinobabies" when discussing efforts to reduce the share of older staff.
The complaint also points to a multi-year EEOC investigation. According to the filing, the agency found reasonable cause to believe IBM had discriminated against older workers. Statistical analysis covering 2013 to 2018 determined that IBM's Resource Actions targeted "primarily older workers (85.85%) in the total potential pool of those considered for layoff," the filing states, citing the EEOC's findings.
On top of that, the complaint alleges IBM sidestepped a federal disclosure requirement - the Older Workers Benefit Protection Act - that would have required the company to share the ages of other employees being laid off. That information, the filing says, would have made the broader pattern visible to individual workers being terminated.
Two of the three workers also bring retaliation claims. Both say they told their direct managers they believed they were being treated differently because of their age. IBM terminated them anyway, according to the complaint.
After receiving their termination notices, none of the three received help finding new roles inside the company, the filing states. One applied for three internal positions. Another applied for seven. The third applied for one. All were rejected without explanation, the complaint alleges, while IBM continued recruiting and hiring younger employees.
The filing brings claims under the Age Discrimination in Employment Act and state anti-discrimination laws in Massachusetts, New York, and Florida. It seeks back pay, lost benefits, reinstatement or front pay, liquidated damages, and attorneys' fees.
For HR teams managing reductions in force, the complaint reads as a detailed inventory of the internal communications, hiring timelines, and selection processes that plaintiffs' lawyers will pull apart when layoffs and new hiring happen in close proximity.
The allegations in the complaint have not been tested in court, and no judge has made any findings or rulings in the matter.
