Briefs and Documents

• Complaint
• Amended Complaint
• Motion for Leave of Court to File Amended Complaint
• Plaintiff's reply Memorandum to Defendant's Opposition to Plaintiff's Motion for Leave of Court to File Amended Complaint
• Memorandum of Points and Authorities in Opposition to Defendant's Memorandum in Support of Defendant's Motion for Judgment
• Answer
• Memorandum in Support of Defendant's Motion for Judgment on the Pleadings
• Reply Memorandum in Support of Defendant's Motion for Judgment on the Pleadings
• Gibby's Appellate Brief
• Gibby's Appellate Brief (in "plain" English)
• IBM's Appellate Brief
• IBM's About Your Company Employee Handbook
• Presentation Guide for Managers, IBM Suggestion Plan (re: Plan Enhancements)
• IBM Suggestion Plan, Your ideas have value
• IBM Suggestion Plan, Evaluator's Guide
• IBM Principles, Manager's Manual MM-02
• Basic Management Responsibilities, MM-03
• IBM Suggestion Plan, MM 02-24
• Speak-Up Program, MM 4-23
• Open-Door Policy, MM 8-01
• IBM IDEAS Announcement
• IBM IDEAS Program Guide
• IBM IDEAS Manager's Guide
• IBM Corporate Business Conduct Guidelines
• IBM Senior Management
• Web Site Review Requests
• Opinion of the United States District Court regarding IBM's Motion for Judgment on the Pleadings
• Opinion of the United States Court of Appeals regarding Gibby's Appeal