The complaint makes class claims under California's consumer protection laws and for assault and battery. The beginning of the complaint provides an overview:
I. Uber will stop at no lengths to make a profit.
2. Since Uber launched in 2010, thousands of female passengers have endured unlawful conduct by their Uber drivers including rape, sexual assault, physical violence an gender-motivated harassment. Recently, the number of reported sexual assaults and rapes of female passengers by male Uber drivers has sky-rocketed.
3. On notice of the magnitude of the number of passengers who have experienced sexual harassment and gender-based violence, Uber should have made drastic changes to the way that it screens and monitors drivers, as well as advancing safety measures on its app and in vehicles, and disclosed the truth to consumers about its insurance coverage during rides.
4. Instead, over the last seven years, Uber has done everything possible to continue using low-cost, woefully inadequate background checks on drivers and has failed to monitor drivers for any violent or inappropriate conduct after they are hired. Nothing meaningful has been done to make rides safer for passengers – especially women.
5. This is no longer an issue of "rogue" drivers who act unlawfully. Uber has created a system for bad actors to gain access to vulnerable victims. Specifically, drivers have the means and opportunity to veer off route without detection, trap passengers inside the vehicles and commit physical and sexual violence without witnesses.