Amicus Curiae Brief — Obergefell v. Hodges

Supreme Court brief2015

Ask Donna

What actually matters in this document.

Text

MAR 5 - 2015

Nos. 14-556, 14-562, 14-571, 14-5 PRLS OF THE CLERK

IN THE

Supreme Court of the Gnited States

JAMES OBERGEFELL, ET AL.,

Petitioners,

We

RICHARD HODGES, DIRECTOR, OHIO DEP’T OF HEALTH,

ET AL.,

Respondents.

On Writs of Certiorari to the United States

Court of Appeals for the Sixth Circuit

BRIEF OF 379 EMPLOYERS AND ORGANIZATIONS

REPRESENTING EMPLOYERS AS

AMICI CURIAE IN SUPPORT OF PETITIONERS

MEGHAN RHEA SUSAN BAKER MANNING

WG+R LAw GROUP, P.C. Counsel of Record

2233 Santa Clara Avenue MICHAEL L. WHITLOCK

Alameda, California 94501 AMANDA D. SMITH

(510) 323-4034 JOHN A. POLITO

JAWAD MUADDI

MORGAN, LEWIS & BOCKIUS LLP

2020 K Street N.W.

Washington, D.C. 20006

(202) 373-6000

susan.manning@morganlewis.com

Counsel for Amici Curiae

ERTL RIDE AAO LES TO IT I TE NENT E TIT TEE HE EMA IR a E

BRITTANI HENRY, ET AL.,

Petitioners,

Vv.

RICHARD HODGES, DIRECTOR, OHIO DEP’T OF HEALTH,

ET AL..,

Respondents.

VALERIA TANCO, ET AL.,

Petitioners,

Vv.

WILLIAM EDWARD “BILL” HASLAM, GOVERNOR OF TEN-

NESSEE, ET AL.,

Respondents.

APRIL DEBOER, ET AL.,

Petitioners,

Vv.

RiIcK SNYDER, GOVERNOR OF MICHIGAN, ET. AL.

Respondents.

GREGORY BOURKE, ET AL., AND TIMOTHY LOVE, ET AL,

Petitioners,

Vv.

STEVE BESHEAR, GOVERNOR OF KENTUCKY, ET AL.,

Respondents.

TABLE OF CONTENTS

INTEREST OF THE AMICI CURIAE........................ 1

SUMMARY OF THE ARGUMENT ......................... 14

FETE cminttinnsatntmnnnionionmunminmedeaetid 15

A. Our Businesses Benefit From Diversity

NF i cennesentnviisinnsietinniinmeniimnnie 20

B. To Reap The Rewards Of Diversity,

Employers Need To Be Able To Re-

cruit And Retain Top Talent, In Part

Through Equitable And Competitive

BOGUT UNNI. ccccssevecnsnvenninevencssensensseceeen 23

3. Employees in same-sex rela-

tionships receive varying, if

any, access to the rights, bene-

fits, and privileges that differ-

ent-sex couples enjoy. ....................+- 27

2. Marriage discrimination drives

talented individuals away from

jurisdictions in which amici do

SUT sscirececsisinduibineneattaniecsteniaatinasinidataiunia 30

of Marriage Discrimination Injures Ami-

OO IED, csinesicecitumnennenicatiieiaiiaiinniinin 35

l. The states’ bans impose signifi-

cant burdens on our employees

and our businesses. .........................- 36

7 State bans undermine our cor-

ED GI ccensecenemennnnnini¢n 41

ERIS sccsicusisiisssemsncesraentitetaasiitditaea tate aae ee 44

APPENDIX A: IDENTIFICATION OF AMIC7........ 1

UTHORIT

CASES

In re Adoption of K.R.S.,

109 So. 3d 176 (Ala. Civ. App. 2012)

Ex parte Ala. ex rel. Ala. Policy Inst.,

No. 1140460 (Ala. Mar. 3, 2015)

Baskin v. Bogan,

766 F.3d 648 (7th Cir. 2014)

Bostic v. Schaefer,

760 F.3d 352 (4th Cir. 2014)

Brenner v. Scott,

999 F. Supp. 2d 1278 (N.D. Fla. 2014)

DeBoer v. Snyder,

772 F.3d 388 (6th Cir. 2014)

Garden State Equal. v. Dow,

82 A.3d 336 (N.J. Super. Ct. Law Div. 2013)

Goodridge v. Dep't of Pub. Health,

798 N.E.2d 941 (Mass. 2003)

Griego v. Oliver,

316 P.3d 865 (N.M. 2013)

Grutter v. Bollinger,

539 U.S. 306 (2003)

-iv-

Kitchen v. Herbert,

755 F.3d 1193 (10th Cir. 2014).......... 17, 18, 28, 42

Latta v. Otter,

TE Fee SBD Gee Cay BBE cccccccccccecccccccccccccces 17, 19

Murphy v. Colvin,

No. 1:14-cv-01764 (D.D.C. Oct. 22, 2014)............ 27

Searcy v. Strange,

No. 14-0202, 2015 WL 328728 (S.D. Ala.

A, Gs GED cccecnccnencescenenssnncnssnnensncsrennsnenseenantitn 17

In re Seb C-M,

NYLJ 1202640527093 (N.Y. Surr. Ct.

SE Gi Ge ctevcnsnccensccsccnssscnsnscssenssssssssennssrssosssseens 31

Strawser v. Strange,

No. 14-0424, 2015 WL 589917 (S.D. Ala.

SEE ee eee ae eee 16

Taylor v. Brasuell, No. 1:14-cv-00273 (D.

SS EES ease 28

United States v. Windsor,

RR ESE EEre eerie: passim

Varnum v. Briten,

763 N.W.2d 862 (Iowa 2009) ...0... 0. 16

Waters v. Ricketts,

No. 8:14-cv-356 (D. Neb. Mar. 2, 2015)................ 16

Whitewood v. Wolf,

992 F. Supp. 2d 410 (M.D. Pa. 2014)................... 17

-V-

FEDERAL STATUTES

ee ete 0 Bae itetncesecineccsescnsensectdenscesesseneninnnsausensest 27

4B UBS. § SRG wccccccccccccnsccccesescnsscesecesscccecs 27

STATE CONSTITUTION

RE ee 36

STATE AND D.C. STATUTES

SE, Se, Cle Oe ED ciiceiccccnetcnsiceccncentasscccsesennians 16

Ee ee ren ee er 17

MF ener 16

I iia iia altel 16

I el 16

MR Ee 16

nis a NN cnn rparieinnnnctinancnitiialiniciaie 16

a, a Gs Oe iiciiccininenpieccnedsnitiinediinminiiunaiiunl 16

ey Cae: ND Tl BUI TE sicriinniiitcccincndibenseniineiibniiiicininddiie 16

i I all 16

i, Ce Ms OF a icicitciciccniccinnnericinsiiiaiibeiiiea 16

ME. REV. STAT., TIT. 19-A § 650-A.....................2220208- 16

MD. CODE ANN., FAM. LAW § 2-201 ..................000.0eeee: 16

- vi -

Sa i ital rnateiciniemepiinibinaie 16

es Ein eee. GRE. GABTRE, BH GEE Riccccecccccccccccescccesesccsnenss 16

ee ee, Ay, MRED TEINOID cicinsisisinisininesicininmnsieanneidainciocichdeiin 17

Be I TIO sic inetieacaisincietaiaiainiibicnmiageil 17

TN i ce 17

WASH. REV. CODE § 26.04.010................. cc ccccceeeeeee eens 17

OTHER AUTHORITIES

Belle R. Ragins, et al, Making the Invisible

Visible: Fear and Disclosure of Sexual

Orientation at Work, 92 J. APPLIED Psy-

te LATTE TRESS LIE OE AIS Rae 26

C. Matthew Schulz, Recruiting & retaining

the best & brightest talent, L.A. DAILY J.

TEN, Hee S ane 25

CEB, Diversity & Inclusion, 3 March

2015, www.executiveboard.com/exbd/hu

man-resources/corporate-leadership-

council/diversity-and-

Is seienienioni 21

Evan Wolfson, Protections Denied to Same-sex

Couples & Their Kids, FREEDOM TO MARRY,

www.freedomtomarry.org/pages/from-why-

marriage-matters-appendix-b-by-evan-

EE REE SE ARSENE Ae on re eR 29

- Vii -

Feng Li & Venky Nagar, Diversity &

Performance, 59 MGMT. SCI. 529

STII iciisiiclediniguenbcnaiebinaiatebiindidigatiiebdibieie 21, 22, 41, 43

Ga. Dep’t of Revenue, Informational Bulletin

No. T-2013-10-25; U.S. Supreme Court &

the Defense of Marriage Act (Oct. 25, 201

3), www.dor.georgia.gov/sites/dor.georgia.

gov/files/related_files/document/LATP/Bu

lletin/DOMA_bulletin_10-25-2013_1.pdf............. 37

Gary J. Gates, Williams Institute, UCLA

School of Law, Marriage Equality & the

Creative Class (May 2009),

www.williamsinstitute.law.ucla.edu/wp-

content/uploads/Gates-MA-Creative-

TEETER REET DOE DT 32

Global Diversity & Inclusion: Fostering In-

novation Through a Diverse Workforce,

FORBES INSIGHTS (July 2011),

www.forbes.com/forbesinsights/

ee rtccccntinisnindsnstmccscennmnes 20, 21, 23

Governor Terry McAuliffe, Governor McAuliffe

Statement on Bostic v. Rainey Ruling

(Feb. 14, 2014), www.governor.virginia.gov/

news/newsarticle?articleld=3302......................... 34

Hon. Eric H. Holder, Jr., U.S. Atty. Gen.,

Remarks at the Human Rights Campaign

Greater N.Y. Gala (Feb. 10, 2014)

www.justice.gov/iso/opa/ag/speeches/2014

lag-epeech- 140210. Tntamnl...........c.cccccccccsccsccccsccsccees 29

- Vili -

Human Rights Campaign, 2014 Municipal

Equality Index: A Nationwide Evaluation

of Municipal Law (2014), www.hrc-

assets.s3-website-us-east-

l.amazonaws.com//files/assets/resources/

SNE daininninesedinaeiecasvnednestssnnndsineennescsernenne: 32

Human Rights Campaign, Corporate

Equality Index (2015), www.hrc.org/camp

aigns/corporate-equality-index ..............-......-...+ 20

Human Rights Campaign, Domestic Partner

Benefits: Grossing Up to Offset Imputed

Income Tax, www.hrc.org/resources/entry

/domestic-partner-benefits-grossing-up-

to-offset-imputed-income-tax ...................2....e0e00 39

Janell L. Blazovich, et al., Do Gay-friendly

Corporate Policies Enhance Firm Perfor

mance? (Apr. 29, 2013), www.west-

info.ew/files/gayfriendly 1.pdf ................... 22, 25, 30

Joanne Sammer & Stephen Miller, The

Future of Domestic Partner Benefits: If

same-sex couples can wed, should

employers provide benefits to unmarried

couples?, SOC’Y FOR HUM. RES. MGMT.

(Oct. 21, 2013), www.shrm.org/hrdiscipli

nes/benefits/articles/pages/domestic-

So EEL EEE 36

- ix -

Katie Kopansky & Jerry Cacciotti, “The Cost of

Inconsistency: Quantifying the Economic

Burden to American Business from the

Patchwork Quilt of Marriage Laws”

(Oct. 2014), www.outandequal.org/wp-

content/uploads/2014/12/nyc.pdf............. 18, 36, 41

Level Playing Field Inst., The Corporate

Leavers Survey: The Cost of Employee

Turnover Due Solely to Unfairness in the

Workplace (2007), www.Ipfi.org/sites/defa

ult/files/corporate-leavers-survey.pdf.................. 26

Marian Moser Jones, Will Same-Sex-

Marriage Rulings Lead to an LGBT

Brain Drain in Some States?, CHRON. HI

GHER EpDuc. (June 27, 2013), www.chroni

cle.com/blogs/conversation/2013/06/27/wil

]-same-sex-marriage-rulings-lead-to-an-

lgbt-brain-drain-in-some-states/ .........................- 34

Matt Apuzzo, More Federal Privileges to

Extend to Same-Sex Couples, N.Y. TIMES

(Feb. 8, 2014), www.nytimes.com/2014/02

/09/us/more-federal-privileges-to-extend-

to-same-sex-couples. html ...............c.ccseceesesceeeeeeees 29

Matt Moty]l, et al., How Ideological

Migration Geographically Segregates

Groups, 51 J. EXPERIMENTAL SOC.

Es Ie IIIT innaddecdsssconnsseninsitusectetunsebeneninenenis 31

-~X-

Max Messmer, Four Keys to Improved Staff

Retention, STRATEGIC FIN. (Oct. 2006),

www.imanet.org/PDFs/Public/SF/2006_1

0/10careers.pdf

MetLife, Insights from MetLife’s 12th

Annual U.S. Employee Benefit Trends

Study (2014), www.benefittrends.metlife.

com/assets/downloads/benefits-

breakthrough-summaries-2014.pdf

Michael J. Moore, Same Sex Marriage Rules

Hamper Wall Street’s Recruiting,

BLOOMBERG Bus. (Apr. 30, 2013)................... 32, 33

Movement Advancement Project et al., A

Broken Bargain: Discrimination, Fewer

Benefits and More Taxes for LGBT

Workers (Full Report) (June 2013),

www.lgbtmap.org/file/a-broken-bargain-

full-report.pdf

M.V. Lee Badgett, et al., The Business

Impact of LGBT-Supportive Workplace

Policies, WILLIAMS INSTITUTE (May 2013),

www.williamsinstitute.law.ucla.edu/wp-

content/uploads/Business-Impact-LGBT-

eceenncncovaressocasonssveosesecsoooosoones 20, 35, 39

Policies-Full-Report-May-2013.pdf.......... 22, 23, 26

NAT'L CONFERENCE OF STATE LEGISLATURES,

Same Sex Marriage Laws, www.ncsl.org/

research/human-services/same-sex-

marriage-laws.aspx

See eee eet Peace ee ee eee een eee e eer eaeteene

~S

Nick Anderson, Outgoing rector warns

Virginia on gay marriage, WASH. POST

CRC TE AE aS ee 84

Only skin deep? Re-examining the business

case for diversity, DELOITTE POINT OF

VIEW (Sept. 2011), www.ced.org/pdf/Deloi

ee Se SR I ood sccnictnntandennsasannecesensne 21

OuT & EQUAL, Majority of Americans Believe

Gay and Lesbian Couples in Committed

Relationships Should Receive Equal

Workplace Benefits as Heterosexual

Married Couples (Oct. 4, 2010), www.har

risinteractive.com/NewsRoom/PressRelea

ses/tabid/446/ct/ReadCustom%20Default

/mid/1506/Articleld/577/Default.aspx............ 25, 26

OuT & EQUAL, Most Americans Say Employers

Should Never Discriminate, Even on Religious

Grounds, According to Latest Harris/Out &

Equal Poll, (Oct. 30, 2014), www.harrisintera

ctive.com/NewsRoom/HarrisPolls/tabid/447/ctl

/‘ReadCustom%20Default/mid/1508/Articleld/1

a icinicinitincuciminninninipeninndasemneneermnises 31

Out on the Street & Immigration Equality,

Thinking Outside of the Closet: The Cost

of LGBT Exclusion; How Discriminatory

Immigration Laws Hurt Business (Feb. 5,

2013), www.outleadership.org/wpcontent/

uploads/2013/11/Thinking-Outside-the-

IT i oiecicccecntecniatnncpinnmmanbbainiinniais 33

xii -

Paula Andruss, How to Attract—And Retain—

Staff When You Can't Pay Big Bucks,

ENTREPRENEUR MAG. (June 27, 2012),

www.entrepreneur.com/article/223516 ......... 24, 25

Peter K. Scott, State Positions on Same-Sex

Married Couple Filing Status Will Affect

Employers, Worldwide ERC® (Feb. 3, 2014),

www.worldwideerc.org/Blogs/MobilityLawB

log/Lists/Posts/Post.aspx?List=c020aee5%2

D48ad%2D47b2%2D8295%2Da4cf7 1 ba9e34

a eneapetitiog 40

Richard Florida, THE RISE OF THE CREATIVE

CLASS—REVISITED (2d ed. 2012)...............0.0.00000.. 38

Scott B. Button, Organizational Efforts to

Affirm Sexual Diversity: A Cross-Level

Examination, 86 J. APPLIED PSYCHOL. 17

Sophia Kerby & Crosby Burns, The Top 10

Economic Facts of Diversity in the

Workplace, CTR. FOR AM. PROGRESS

(July 12, 2012), www.americanprogress.org

/issues/labor/news/2012/07/12/11900/the-

top-10-economic-facts-of-diversity-in-the-

I hccciciisicelsciiteedineteitainshainsiasieaiiiniataitdinnninaudigiibineieintaininin 25

States, Freedom TO MARRY,

www.freedomtomarry.org/states/ .....................05 17

- Xili -

Tara Siegel Bernard, A Progress Report on

Gay Employee Health Benefits, N.Y.

TIMES (updated Mar. 4, 2013), www.buck

s.blogs.nytimes.com/2010/12/14/a-

progress-report-on-gay-employee-health-

Todd Sears, et al., Thinking Outside the

Closet: How Leaders Can Leverage the

LGBT Talent Opportunity, OUT ON THE

STREET (2012), www.outleadership.org/w

p-content/uploads/2013/11/Thinking-

Outside-the-Closet-Volume-One.pdf.............. 21, 42

Todd A. Solomon & Brett R. Johnson,

Walking Employers Through the

Regulatory Maze Surrounding Same-Sex

Domestic Partner Benefits, PROBATE &

PROPERTY 14 (Mar./Apr. 2012), www.ame

ricanbar.org/content/dam/aba/publication

s/probate_property_magazine/v26/02/201

2 aba_rpte_pp_v26_2 mar apr_solomon_

johnson.authcheckdam. pdf .....................0eceeeeeeeees

Todd A. Solomon & Brian J. Tiemann, Issues

to Consider in Providing a Tax Gross-Up

for Emps. Covering Same-Sex Spouses &

Partners under the Employer’s Medical,

Dental, & Vision Plans, 4 (No. 2)

BLOOMBERG L. REPORTS—

EMPLOYEE BENEFITS (2011), www.mwe.c

om/info/pubs/solomon_tiemann_tax_gross

i tnrniiccicnnednnsiiasannmmmaniinionnceisen

- xiv -

U.K. Gov’t Equalities Office, Dep’t for Bus.

Innovation & Skills, The Business Case

for Equality and Diversity: A survey of

the academic literature, BIS OCCASIONAL

PAPER No. 4 (Jan. 2013), www.gov.uk/gov

ernment/uploads/system/uploads/attach

ment_data/file/49638/the_business_case __

for_equality_and_diversity.pdf ............................ 43

U.S. Bureau of Labor Statistics, Employee

Benefits in the U.S. (July 25, 2014),

www.bls.gov/news.release/ebs2.nr0.htm ............. 24

U.S. Gen. Accounting Office, GAO-04-353R,

Defense of Marriage Act: Update to Prior

Report (Jan. 23, 2004), www.gao.gov/

assets/100/92441.pdf

U.S. Office of Personnel Mgmt., Grossing Up

Awards, Why & Why Not, www.opm.gov/

policy-data-oversight/performance-

management/performance-management-

cycle/rewarding/grossing-up-awards ............. 39, 40

INTEREST OF THE AMICI CURIAE'

This brief is submitted with the written consent of

all parties pursuant to Rule 37.3(a).

Amici include technology, materials, airline,

financial services, healthcare, medical technology,

consumer products, apparel, and entertainment

companies, hoteliers, restaurateurs, service

providers, and _ retailers, ranging from small

businesses to Fortune 100 companies. Amici share a

profound desire to attract and retain a talented

workforce.

Some of the states in which amici do business

make marriage equally available to all of our

employees and colleagues; others prohibit marriages

between couples of the same sex and refuse to

recognize existing same-sex marriages. This dual

regime burdens amici. It creates legal uncertainty

and imposes unnecessary costs and administrative

complexities on employers, and requires differential

employer treatment of employees who are similarly

situated save for the state where they reside.

State laws that prohibit or decline to recognize

marriages between same-sex couples hamper

employer efforts to recruit and retain the most

1 Pursuant to Rule 37.6, counsel for amici certify that no

counsel for any party had any role in authoring this brief in

whole or in part, and that no person other than amici, their

members, or their counsel made any monetary contribution in-

tended to fund the preparation or submission of this brief. The

parties have consented to the filing of this brief, and their letters

of consent have been filed with the Clerk.

= >

talented workforce possible in those states. Our suc-

successes depend upon the welfare and morale of all

employees, without distinction. The burden imposed

by inconsistent and discriminatory state laws of

having to administer complicated schemes to account

for differential treatment of similarly situated

employees breeds unnecessary confusion, tension,

and diminished employee morale.

Amici submit this brief to advise the Court of the

adverse impact on employers of these conflicting legal

schemes.

Amici curtae are the following employers and

organizations representing employers:

A.L. Nella & Company, LLP, CPAs

A.T. Kearney

Aardema Whitelaw, PLLC

Acacia Home LLC*

Accenture

Aetna Inc.

Air Products and Chemicals, Inc.

Ad Leo Electric and Solar

Akamai Technologies, Inc.

Alaska Airlines

Alcoa Inc.

Amazon Services Inc. *

Amazon.com, Inc.

American Airlines Group Inc.

American Apparel"

American Express Company

* Denotes amici represented by WG+R Law Group, P.C., rather

than Morgan, Lewis & Bockius LLP.

~ -

American International Group, Inc.*

Aparicio-Mercado Law, L.C.*

Apple Inc.

AppNexus Inc.”

Aramark

Arbor Brewing Company, LLC

Arnold & Porter LLP

Aspen Skiing Company

Assemble Sound LLC

AT&T Inc.

Atlas Cut Stone

Atticus Circle |

The Austin Gay and Lesbian Chamber of Commerce

Avanade Inc.

Bain & Company, Inc.*

Bakehouse Art Complex”

Baker & McKenzie LLP

Bank of America

The Bank of New York Mellon Corporation

Barclays

Barnes & Noble, Inc.

bebe stores, inc.

Becton, Dickinson and Company

Belcampo Inc.

Ben & Jerry’s

Big Duck Studio, Inc.

Bigelow Villa LLC

Billy’s Farm”

BlackRock, Inc.

Bloomberg L.P.

Blue Apron, Inc.

Blue Heron Ventures

Blue Moon Hotel / Winter Haven Hotel"

Blume, Faulkner & Skeen, PLLC"

~ =

Boehringer Ingelheim Pharmaceuticals, Inc.*

Boston Community Capital, Inc.

Boston Consulting Group”

The Boston Foundation"

Boston Medical Center Corporation®

Boston Scientific Corporation

Brady Mills LLC

BrandQuery LLC

Bristol-Myers Squibb Company

Broadcom Corporation

Brocade

Cablevision Systems Corporation

Capital One Financial Corporation

Captain Wendell’s Marine Services LLC

Cardinal Health, Inc.*

Care Resource

CBS Corporation

CEB

Central Physical Therapy and Fitness, PSC

CGI

Charlotte Business Guild

The Chubb Corporation”

CIGNA Corporation

Cisco Systems, Inc.

Citigroup Inc.

City Catering Company

City Lites Neon, Inc.

The City of Ann Arbor, Michigan

Civitas Public Affairs Group

Clean Yield Asset Management

CloudFlare, Inc.

CMIT Solutions of Seattle Downtown

The Coca-Cola Company

Cohen & Associates

sie

Colgate-Palmolive Company

Columbia FunMap, Inc.*

Comcast Corporation

The Computer Butler

ConAgra Foods, Inc.*

The Corcoran Group

Corner Brewery, LLC*

Corning Incorporated“

Cox Enterprises, Inc.

Crazy Misfits Pet Services

Credit Suisse Securities (USA) LLC

Cummins Inc.

Cupcake Royale”

CVS Health Corporation

Dallas Voice

Dana-Farber Cancer Institute, Inc.*

Danaher Corporation

David J. Jarrett, P.C.

David Kosar Insurance Agency

David Mack Henderson Income Tax Preparation

DCI Group AZ, L.L.C.”

Deloitte LLP

Delta Air Lines, Inc.

Depository Trust & Clearing Corporation”

The Desert Business Association*

Deutsche Bank AG

Diageo North America, Inc.

DIRECTV

DocuSign*

Domini Social Investments LLC

The Dow Chemical Company

Dreamcatcher Arts and Publishing Ltd."

Dropbox, Inc.

DuPont

eBay Inc.

Edelman

Eldercare Consulting

Electronic Arts Inc.

EnduringHydro, LLC

Ernst & Young LLP

The Estée Lauder Companies Inc.

Event Rents”

Everything Real Estate LLC

Express Movers Inc.

Facebook, Inc.

Farella Braun + Martel, LLP

Fastsigns”

Fenwick & West LLP

First Data Corporation”

lst Security Bank

lstdibs.Com, Inc.

FIT Technologies

Flanery CPA

Full Court Press Communications

G.A.W.., Inc."

The Gay and Lesbian Chamber of Commerce Nevada"

General Electric Company

General Mills, Inc.

Gensler

Gilt Groupe Holdings, Inc.

GlaxoSmithKline LLC

Gleason & Associates Claims Services

Go Factory, Inc.

Goethel Engelhardt, PLLC

The Goldman Sachs Group, Inc.

Google Inc.

Goulston & Storrs, P.C.*

Great Officiants LLC

~ 2

The Greater Connecticut Gay and Lesbian Chamber

of Commerce

Greater San Diego Business Association"

Greater Seattle Business Association

Greensulate

Grossman Marketing Group

Group Health Cooperative”

Groupon*

Growing Hope

Harrell Remodeling

The Hartford Financial Services Group, Inc.*

Healthline

Hewlett-Packard Company

Hilton Worldwide Holdings Inc.*

Holdredge Wines

Homeward Pet Adoption Center

Horizon Air Industries, Inc.

House Packard LLC

HSBC

Ikard Wynne LLP

The Independence Business Alliance

The Inland Northwest Business Alliance

Insala, Ltd

Inspirato, LLC

Integrated Archive Systems, Inc.

Integrity Law Group”

Intel Corporation*

Intuit Inc.

INUS Group, LLC

Jackson Hole Group LLC

Jagod Designs

Jazz Pharmaceuticals, Inc.

Jenn T. Grace Internationa! LLC

Jennifer Brown Consulting

o@e

JetBlue Airways Corporation

The Jim Henson Company

Johnson & Johnson

Johnston, Kinney and Zulaica LLP

Jonathan L. Bowman, Attorney at Law, PS

JPMorgan Chase & Co.

Julian Chang Consulting, Inc.

kapchur.us photography

The Kathy A. Janssen Foundation

Kazan, McClain, Satterley, & Greenwood, PLC

Keir Jones Agency — State Farm

Keker & Van Nest LLP”

KEO Marketing Inc.

Kimberly-Clark Corp.

Kimpton Hotel & Restaurant Group, LLC

Kollmar Sheet Metal Works, Inc.

Kotzan Chiropractic”

KPMG LLP

Lambda Business Association

Laparoscopic Institute for Gynecologic Oncology

Larson Marketing & Communications LLC

Laughton Properties”

Law Offices of Joel L. Sogol

Law Office of Lisa E. Schuchman

Law Office of Lorie L. Burch, PC

Law Offices of Robin L. Bodiford, P.A.*

The Law Office of Susan K. Fuller, PLLC

Levi Strauss & Co.

Liberty Burger®

Lieff Cabraser Heimann & Bernstein, LLP

Life & Love Celebrations”

Link in the Chain Foundation, Inc.

Littler Mendelson, P.C.

LNT, Inc.

~

The Long Beach Gay & Lesbian Chamber of

Commerce

Lori Karbal et al*

Loring, Wolcott & Coolidge Trust, LLC

The Los Angeles Gay & Lesbian Chamber of

Commerce“

Main Street Hair Shoppe Ltd.

Marriott International, Inc.

Marsh & McLennan Companies, Inc.

Massachusetts Mutual Life Insurance Company

McGraw Hill Financial, Inc.”

McKesson Corporation“

McKinsey & Company, Inc.”

Merca Property Management

The Miami-Dade Gay & Lesbian Chamber of

Commerce

Microsoft Corporation*

The Mid-America Gay & Lesbian Chamber of

Commerce

Miller & Olson, LLP

Miller Shelton Group, LLC*

MillerCoors LLC

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Mona Smith PLLC

Moody’s Corporation

Morgan Miller Plumbing

Morgan Stanley

MWW Public Relations

NAMI Dallas, Inc. *

The Nashville LGBT Chamber of Commerce

The National Gay & Lesbian Chamber of Commerce

Nationwide Mutual Insurance Company

Neumann Capital Management, LLC

The New England Patriots

-10-

New Leaf Columbus

New York Life Insurance Company

Nifty Hoops, LLC

NIKE, Inc."

Nixon Peabody LLP*

North Texas GLBT Chamber of Commerce”

Northrop Grumman Corporation

OBOX Solutions

Office Depot, Inc.

The Ogilvy Group, Inc.

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

ONE Community Media, LLC

1 Source Consulting Solutions"

Oracle America, Inc.

Orbitz Worldwide, Inc.”

Out & Equal Workplace Advocates

Outerwall Inc.

Pakmode Publications, LLC

d/b/a Pakmode Media + Marketing

Pandora Media, Inc.

PATH

Peabody & Arnold LLP”

Pepper Hamilton LLP

PepsiCo

Pfizer Inc.

Pixelligent Technologies LLC

Plexus Education Foundation

Plexus LGBT and Allied Chamber of Commerce

Portland Area Business Association"

PricewaterhouseCoopers LLP

PrideFest

The PrintingWorks

Pro-Tec Data, Inc.

Procter & Gamble

ij.

ProTrials Research, Inc.*

Prudential Financial, Inc.

Puma Spring Vineyards

Qualcomm Incorporated

Quorum

RAFI Architecture and Design”

Rainbow Chamber of Commerce Silicon Valley

Ralph’s Regal Weddings

Ray Holley Communications”

RBC Capital Markets, LLC

Replacements, Ltd. *

Restaurant Management Concepts

Reverberate! Marketing Communications, Inc.

Rising Tide Brewing Company”

RJR Photography

Robert H Stutz Jr CPA“

Rockwell Automation, Inc.

Rotella & Hernandez, LLC

The Sacramento Rainbow Chamber of Commerce*

Sadek Bonahoom PLC

The San Francisco Chamber of Commerce

The San Francisco Giants

The Seattle Lesbian, LLC

Seattle Metropolitan Chamber of Commerce”

Sempra Energy”

Seyfarth Shaw LLP

Shingles Roofing LLC*

Sidetrack, Inc. *

Simon, Schindler & Sandberg LLP

Skellenger Bender, P.S.

Skyworks Solutions, Inc.*

Sleeves Up Productions, LLC*

Sow

Spectra Law PS

- ]2-

Spry Vision, Inc.

St. Jude Medical, Inc.

Staples, Inc.*

Starbucks Corporation

Starrtek LLC*

State Street Corporation

Steven Graves Insurance Agency*

Stonewall Behavioral! Health

Stonewall Columbus

Stuffed Cakes, LLC’

Sun Life Financial (U.S.) Services Company, Inc.

SunDaily

Support.com, Inc.

Sweet Dixie Kitchen“

Symantec Corporation

Taber Food Services, Inc.

dba Hobee’s California Restaurants

The Tampa Bay Rays

Target Corporation

TD Bank, N.A.

TD Securities (USA) LLC

Tech Data Corporation”

TestTracks

Thinking Cap Communications & Design

Third Point LLC

Thomson Reuters”

Tiwary Entertainment Group LLC

TNT Promotions, LLC"

TOCA Events, LLC*

TravelOut, Inc.

Tutta Bella Neapolitan Pizzeria

Twitter, Inc.

206 Inc. ”*

UBS AG

cS

The Ultimate Software Group, Inc.

United Air Lines, Inc.

United Therapeutics Corporation

Uptown Physicians Group”

VCB Consulting & Accounting Services”

Verizon Communications Inc.

Viacom Inc.

Visa Inc.”

VitaPerk”

VMware, Inc. ”*

W. M. Martin Advertising

W.W. Grainger, Inc.”

W/S Development Associates LLC"

Walsh Wellness Center”

The Walt Disney Company”

Wasserman Media Group

Wells Fargo & Company

Whey Natural! USA LLC

Wisconsin LGBT Chamber of Commerce

Witeck Communications, Inc.

The Workplace Equality Index

Wyndham Worldwide Corporation

Xerox Corporation"

Xfund

YES DESIGN GROUP

Ypsilanti Downtown Development Authority

Zausmer, Kaufman, August & Caldwell, P.C.

Zingerman’s Community of Businesses

ZoomSystems

Zynga Inc.

otis

SUMMARY OF THE ARGUMENT

More than seventy percent of Americans live in a

state that celebrates and recognizes same-sex

marriages. But many states continue to prohibit

same-sex couples from marrying, and decline to

recognize the valid, existing marriages of citizens

married to a spouse of the same sex. This fractured

legal landscape harms employers and employees

alike.

Over the past several years, federal and state

courts have evaluated the constitutionality of same-

sex marriage bans to varying effect. Amici already

operate against a complicated, uncertain, and

frequently changing backdrop of laws and

employment-related regulations that increase our

administrative costs. Inconsistent state marriage

laws impose an added economic burden on American

businesses at an estimated cost of over one billion

dollars per year.

Discriminatory state laws force amici to

implement inconsistent policies across the various

jurisdictions in which we operate, our stated

corporate principles of diversity and _ inclusion

notwithstanding. Our ability to grow and maintain

our businesses by attracting and retaining the best

employee talent is hindered. The patchwork of state

laws applicable to same-sex marriage thus impairs

our business interests and employer/employee

relations. If the Court were to affirm the decision

below, the costs and uncertainty imposed by

inconsistent state marriage laws will only continue.

In contrast, reversal will reduce current costs,

1

administrative burden, and diversion of resources

from our core businesses.

We therefore respectfully urge the Court to re-

verse the decision below and affirm a uniform princi-

ple that all couples share in the right to marry.

ARGUMENT

Nearly two years ago, the Court held in United

States v. Windsor that the federal government may

not, consistent with the Constitution, refuse to recog-

nize valid marriages between persons of the same

sex.2 The Court noted that some jurisdictions had de-

termined that same-sex couples should have “the

right to marry and so live with pride in themselves

and their union and in a status of equality with all

other married persons.” The Court concluded that

no legitimate purpose overcomes the

purpose and effect to disparage and to

injure those whom the State, by its

marriage laws, sought to protect in per-

sonhood and dignity. By seeking to dis-

place this protection and treating those

persons as living in marriages less re-

spected than others, the federal statute

is in violation of the Fifth Amendment.‘

2 133 S. Ct. 2675 (2013) (invalidating Section 3 of the

Defense of Marriage Act of 1996).

3 Id. at 2689.

4 Id. at 2696.

- 16-

Marriage is now equally available to all couples,

regardless of each partner’s sex, in thirty-seven

states and the District of Columbia.5 In sixteen of

those states and the District of Columbia, state law

provides same-sex couples with equal access to mar-

riage—state laws that stand independent of whatever

constitutional judgment the Court issues in this

case. In the other twenty-one states, same-sex cou-

6 Marriages between same-sex couples are currently li-

censed by Alabama, Alaska, Arizona, California, Colorado, Con-

necticut, Delaware, Florida, Hawaii, Idaho, [linois, Indiana,

Iowa, Kansas, Maine, Maryland, Massachusetts, Minnesota,

Montana, Nevada, New Hampshire, New Jersey, New Mexico,

New York, North Carolina, Oklahoma, Oregon, Pennsylvania,

Rhode Island, South Carolina, Utah, Vermont, Virginia, Wash-

ington, West Virginia, Wisconsin, Wyoming, and the District of

Columbia. See, e.g., NAT’L CONFERENCE OF STATE LEGISLATURES,

Same-Sex Marriage Laws, www.ncsl.org/research/human-

services/same-sex-marriage-laws.aspx. In addition, the U.S. Dis-

trict Court for the District of Nebraska has issued an order that,

effective March 9, 2015, “all relevant state officials are ordered

to treat same-sex couples the same as different sex couples in

the context of processing a marriage license or determining the

rights, protections, obligations or benefits of marriage.” Waters

v. Ricketts, No. 8:14-cv-356 (D. Neb. Mar. 2, 2015), appeal dock-

eted, No. 15-1452 (8th Cir. 2015). On March 3, 2015, the Ala-

bama Supreme Court “temporarily enjoined” each Alabama

state probate judge (other than a probate judge currently subject

to a federal injunction) from “issu[ing] ... marriage licenses to

same-sex couples.” Ex parte Ala. ex rel. Ala. Policy Inst., No.

1140460 (Ala. Mar. 3, 2015); see also Strawser v. Strange, No.

14-0424, 2015 WL 589917 (S.D. Ala. Feb. 12, 2015) (federal in-

junction).

6 See CONN. GEN. STAT. § 46b-20; DEL. CODE ANN., tit. 13,

§ 101; HAw. REV. STAT. §§ 572-A-572-E, 572-1, 572-3, 572-6,

672-13, 572B-4, 572B-9.5, 572C-2, 580-1; 750 ILL. Comp. STAT.

§§ 5/201, 209, 212, 213.1, 220 & 75/60, 65; Varnum v. Brien, 763

N.W.2d 862 (lowa 2009); ME. REV. STAT., tit. 19-A, § 650-A; MD.

9.

ples are currently able to marry only as a result of

federal court decisions invalidating restrictions on

same-sex marriage.’ The remaining thirteen states

continue to refuse to allow same-sex partners to mar-

ry, or to recognize their valid existing marriages.®

CODE ANN., FAM. LAW § 2-201; Goodridge v. Dep't of Pub. Health,

798 N.E.2d 941 (Mass. 2003); MINN. STAT. § 517.01, et seq.; N.H.

REV. STAT. ANN. § 457:1-a; Garden State Equal. v. Dow, 82 A.3d

336 (N.J. Super. Ct. Law Div. 2013); Griego v. Oliver, 316 P.3d

865 (N.M. 2013); N.Y. Dom. REL. LAW § 10-a; R.1. GEN. Laws

§ 15-1-1, et seq.; VT. STAT. ANN. tit. 15, § 8; WASH. Rev. CopE

§ 6.04.010; D.C. Cope § 46-401.

7 Kitchen v. Herbert, 755 F.3d 1193 (10th Cir. 2014) cert.

denied, 135 S. Ct. 265 (2014); Bostic v. Schaefer, 760 F.3d 352

(4th Cir. 2014) cert. denied sub nom. Rainey v. Bostic, 135 S. Ct.

286 (2014), sub nom. Schaefer v. Bostic, 135 S. Ct. 308 (2014),

and sub nom. McQuigg v. Bostic, 135 S. Ct. 314 (2014); Baskin v.

Bogan, 766 F.3d 648 (7th Cir. 2014), cert. denied, 135 S. Ct. 316

(2014), and cert. denied sub nom. Walker v. Wolf, 135 S. Ct. 316

(2014); Latta v. Otter, 771 F.3d 456 (9th Cir. 2014) (rehearing

denied); Whitewood v. Wolf, 992 F. Supp. 2d 410 (M.D. Pa.

2014); Brenner v. Scott, 999 F. Supp. 2d 1278 (N.D. Fla. 2014),

appeal docketed sub nom. Brenner v. Armstrong, No. 14-14061-

AA (llth Cir. 2015) (stayed); Searcy v. Strange, No. 14-0202,

2015 WL 328728 (S.D. Ala. Jan. 23, 2015), appeal docketed sub

nom. Searcy v. Att'y Gen. of Ala., No. 15-10295-C (11th Cir.

2015, (stayed).

& At this time, Arkansas, Georgia, Kentucky, Louisiana,

Michigan, Mississippi, Missouri, Nebraska, North Dakota, Ohio,

South Dakota, Tennessee, and Texas decline to issue marriage

licenses to same-sex couples. Among them, only Missouri recog-

nizes marriages between persons of the same sex that were law-

fully performed in other jurisdictions, States, FREEDOM TO MAR-

RY, www.freedomtomarry.org/states/. A federal court has or-

dered that Nebraska license and recognize same-sex marriages

starting March 9, 2015. See supra n.5.

- 18 -

As employers, amici know firsthand that this frac-

tured legal landscape hampers economic growth and

impedes innovation by forcing businesses to work

harder, and invest more, to achieve the same return

on our investments. Inconsistent marriage laws force

companies to divert significant time and money to the

creation and maintenance of complex administrative

systems needed to differentiate treatment of other-

wise indistinguishable employees based on the differ-

ent marriage laws of the places where they live.

These differences can create rifts in the employer-

employee relationship. Employers are better served

by a uniform marriage rule that gives equal dignity

to employee relationships. Allowing same-sex couples

to marry improves employee morale and productivity,

reduces uncertainty, and removes the wastefui ad-

ministrative burdens imposed by the current dispari-

ty of state law treatment.

Although the Court did not decide in Windsor

whether the Constitution requires that same-sex

couples be allowed to marry, numerous courts have

taken up that issue since. Four out of five United

States Courts of Appeal have held that marriage

must be equally available to same-sex couples.!°

® See Katie Kopansky & Jerry Cacciotti, The Cost of

Inconsistency: Quomtifying the Economic Burden to American

Business from the Patchwork Quilt of Marriage Laws 2, at 1

(Oct. 2014) (“For American businesses, inconsistent marriage

laws impose a significant economic burden—specifically a $1.3

billion annual cost.”), www.outandequal.org/wp-

content/uploads/2014/12/nyc.pdf.

10 ~§=—6. Kitchen, 755 F.3d at 1199 (holding that same-sex couples

have a fundamental right to “marry, establish a family, raise

= ™

In one such ruling, the Ninth Circuit observed:

The lessons of our constitutional history

are clear: inclusion strengthens, rather

than weakens, our most important in-

stitutions. When we integrated our

schools, education improved. When we

opened our juries to women, our democ-

racy became more vital. When we al-

lowed lesbian and gay soldiers to serve

openly in uniform, it enhanced unit co-

hesion. When same-sex couples are

married, just as when opposite-sex cou-

ples are married, they serve as models

of loving commitment to all."!

These same observations ring true for American com-

panies: diversity and inclusion strengthen, not weak-

en, our businesses.

children, and enjoy the full protection of a state’s marital laws”);

Bostic, 760 F.3d at 377 (“Over the decades, the Supreme Court

has demonstrated that the right to marry is an expansive liberty

interest that may stretch to accommodate changing societal

norms ... [and] is not circumscribed based on the characteristic

of the individuals seeking to exercise that right.”); Baskin, 766

F.3d at 656 (“discrimination against same-sex couples is irra-

tional and therefore unconstitutional even if the discrimination

is not subjected to heightened scrutiny”); Latta, 771 F.3d at 473

(finding unconstitutional prohibition on marriages between per-

sons of the same sex). But see DeBoer v. Snyder, 772 F.3d 388

(6th Cir. 2014) (reversing district court opinions that had de-

clared marriage discrimination unconstitutional), cert. granted

sub nom. Obergefell v. Hodges, Nos. 14-556, 14-562, 14-571, 14-

574, 2015 WL 213651 (U.S. Jan. 16, 2015).

1 §=©=>©.Latta, 771 F.3d at 476 (quotation marks and citations

omitted).

2.

A. Our Businesses Benefit From Diversity

and Inclusion.

“Today, diversity and inclusion ... are a given.”!”

They are among the core principles of amici in the

conduct of their businesses. The value of diversity

and inclusion in the workplace has been well-

documented following rigorous analyses. Amici and

others recognize that diversity is crucial to innovation

and marketplace success.!3 Members of the lesbian,

gay, bisexual, and transgender (“LGBT”) community

are one source of that diversity. A May 2013 Small

Business Majority survey reported that sixty-nine

percent of small business owners support non-

discrimination laws protecting LGBT workers." As of

2015, eighty-nine percent of Fortune 500 companies

provide non-discrimination protection for their LGBT

employees, and sixty-six percent offer benefits to

same-sex partners.!5

12, Global Diversity & Inclusion: Fostering Innovation

Through a Diverse Workforce, FORBES INSIGHTS, 11 (July 2011)

(hereinafter "Forbes Insights”), www forbes.com/forbesinsights/i

nnovation_diversity (a comprehensive study of 300 senior

diversity officers at companies worldwide with revenues of at

least $500 million).

3) Jd. at 5.

14 Movement Advancement Project, et al. A Broken

Bargain: Discrimination, Fewer Benefits and More Taxes for

LGBT Workers (Full Report), at ii (Jume 2013) (hereinafter

“Broken Bargain”), www .lgbtmap.org/file/a-broken-bargain-full-

report.pdf.

15 Human Rights Campaign, Corporate Equality Index, 8,

11 (2015), www-hrc.org/campaigns/corporate-equality-index.

ye

Amici invest time and resources to achieve and

maintain diversity and inclusion. It is the right thing

to do and it yields tangible results. A diverse, inclu-

sive workplace environment “increases the total hu-

man energy available to the organization. People can

bring far more of themselves to their jobs because

they are required to suppress far less.”'* Inclusive

companies are more open to new ideas and opportuni-

ties, while less prone to overconfidence when ap-

proaching challenges.'!?7 Companies that are diverse

and inclusive obtain better profits and other outputs,

thanks to improved team collaboration and commit-

ment.'® By contrast, “corporate cultures that don’t

encourage openness and inclusiveness leave employ-

ees feeling isolated and fearful,” and lose marketing

potential in reaching out to LGBT consumers.’9

16 =6Only skin deep? Re-examining the business case for

diversity, DELOITTE POINT OF VIEW, 7 (Sept. 2011) (citing

Frederick A. Miller & Judith H. Katz, THE INCLUSION

BREAKTHROUGH (2002)), www.ced.org/pdf/Deloitte_Only_Skin_D

eep.pdf.

17 See Feng Li & Venky Nagar, Diversity & Performance,

59 MGMT. SCI. 629, 531 (2013).

1 CEB, Diversity & Inclusion, 3 March 2015,

www.executiveboard.com/exbd/human-resources/corporate-

leadership-council/diversity-and-inclusion/index.page

(workforces with high diversity and inclusion show marked

improvement in team collaboration and commitment); see also

Forbes Insights, supra n.12, at 5 (giving examples).

18 Todd Sears, et al., Thinking Outside the Closet: How

Leaders Can Leverage the LGBT Talent Opportunity, OUT ON

THE STREET, 3 (2012), www.outleadership.org/wp-

content/uploads/2013/11/Thinking-Outside-the-Closet-Volume-

One.pdf.

RB.

Empirical evidence shows the business value of

investments in diversity. The Williams Institute at

the UCLA School of Law recently reviewed thirty-six

research studies and found that working in an LGBT-

supportive workplace results in “greater job commit-

ment, improved workplace relationships, increased

job satisfaction, improved health outcomes, and in-

creased productivity” among LGBT employees.?° A

2013 study of approximately 300 firms that adopted

same-sex domestic partnership benefits between 1990

and 2006 showed an approximate ten percent average

stock price increase over the sample period—a per-

formance better than ninety-five percent of all U.S.

professional mutual funds—as well as “significant

improvement in operating performance relative to

companies that did not adopt such policies.?!

20 =6M.V. Lee Badgett, et al., The Business Impact of LGBT-

Supportive Workplace Policies, WILLIAMS INSTITUTE, 1 (May

2013) (hereinafter "Williams Institute”), www.williamsinstitute.

law.ucla.edu/wp-content/uploads/Business-I[mpact-LGBT-

Policies-Full-Report-May-2013.pdf.

22> «Li & Nagar, supra n.17, at 529, 534, 537-41 (reporting

an approximate ten per cent risk-adjusted excess return as

compared to companies that did not adopt same-sex domestic

partnership benefits); see also Williams Institute, supra n.20, at

23 (“A... study found that the more robust a company’s LGBT-

friendly policies, the better its stock performed over the course

of four years (2002-2006), compared to other companies in the

same industry over the same period of time.”); Janell L.

Blazovich, et al., Do Gay-friendly Corporate Policies Enhance

Firm Performance?, 35-36 (Apr. 29, 2013), www.west-

info.eu/files/gayfriendly1.pdf (“[F]irms with gay-friendly policies

benefit on key factors of financial performance, which ...

increase the investor perception of the firm as proxied by stock-

price movements.”).

+. -

Diverse workforces also help capture new cli-

ents.22 A 2011 study found that sixty-eight local gov-

ernments require that their contractors have LGBT:

supportive hiring and benefits policies.2

Our corporate principles of diversity and inclusion

are the right thing to do. Beyond that, however, such

policies contribute to employee happiness and loyalty,

greater company productivity and, ultimately, signifi-

cant returns for our shareholders and owners.

B. To Reap The Rewards Of Diversity, Em-

ployers Need To Be Able To Recruit And

Retain Top Talent, In Part Through Equi-

table And Competitive Benefits Packages.

In order to develop and grow a diverse organiza-

tion, employers need to be able to recruit and retain

the best talent.24 Amici hire and promote employees

based on ability. In the long run, discrimination im-

pairs an employer's ability to compete for the best

workforce. The market for top talent crosses state

and even national boundaries. Benefits are critical to

efforts to compete for top talent, as benefits directly

contribute to successful recruiting and employee loy-

22 Forbes Insights, supra n.12, at 11.

23 Williams Institute, supra n.20, at 21. California has

similar state-wide requirements. Id. (citing CAL. PUB. CONT.

CODE § 10295.3(a)(1), (e)(1)).

246 “T]he _ skills needed in today’s increasingly global

marketplace can only be developed through exposure to widely

diverse people, cultures, ideas, and viewpoints.” Grutter v.

Bollinger, 539 U.S. 306, 330 (2003), superseded on other grounds

by MICH. CONST. art. I, § 26.

- 24-

alty.25 As of 2014, eighty-six percent of full-time

American workers in private industry received medi-

cal benefits through their employer, and seventy-four

percent had employer-provided retirement plans. 76

Benefit packages—especially health care and retire-

ment benefits—can add thirty percent or more in

value to an employee’s overall compensation. In a

2011 Harvard Business Review survey, sixty percent

of human resources leaders stated that an attractive

benefits package is “very important” in recruiting and

retaining quality employees.27 In 2010, seventy-seven

percent of LGBT respondents found it important to

work for a company with a _ written non-

discrimination policy that covers sexual orientation,

and eighty percent said it was important for their

employer to offer equal health insurance benefits to

2 MetLife, Insights from MetLife’s 12th Annual U.S.

Employee Benefit Trends Study, 2, 9 (2014),

www.benefittrends.metlife.com/assets/downloads/benefits-

breakthrough-summaries-2014.pdf (50% of employees felt

benefits were an important reason for remaining with the

company).

26 U.S. Bureau of Labor Statistics, Employee Benefits in the

U.S. (July 25, 2014), www.bls.gov/news.release/ebs2.nr0. htm.

27 Paula Andruss, How to Attract—And Retain—Staff

When You Cant Pay Big Bucks, ENTREPRENEUR MAG.

(June 27, 2012) (compared with 38% who believed only high

base salary was “very important”), www.entrepreneur.com/articl

e/223516; Max Messmer, Four Keys to Improved Staff

Retention, STRATEGIC FIN., 13 (Uct. 2006), www.imanet.org/PDF

s/Public/SF/2006_10/10careers.pdf (“A 2005 [Zogby International

] survey ... revealed that 58% of employees polled would prefer a

job with excellent benefits over one with a higher salary.”).

- 2§ .

all employees.?8 Through such policies and benefits,

employers foster positive employer-employee rela-

tionships and enhance their ability to retain satisfied

and engaged workers, who in turn are more produc-

tive and perform better than their less-satisfied col-

leagues. ?9

Amici understand the need to offer workplace

benefits equitably, particularly to a diverse work-

force, because employees who are treated differently

are more likely to leave as a result of perceived dis-

crimination. These departures “result[{] in avoidable

turnover-related costs at the expense of a company’s

profits.” In 2007, a national survey of people who

had quit or been laid off since 2002 reported that

“[g]ay and lesbian professionals and managers said

workplace unfairness was the only reason they left

their employer almost twice as often as heterosexual

2 Out & Equal, Majority of Americans Believe Gay &

Lesbian Couples in Committed Relationships Should Receive

Equal Workplace Benefits as Heterosexual Married Couples (Oct.

4, 2010), www.harrisinteractive.com/NewsRoom/PressReleases/

tabid/446/ctl/ReadCustom%20Default/mid/1506/Articleld/577/De

fault.aspx.

29 MetLife, supra n.25, at 12—13; see generally Andruss,

supra n.27; Messmer, supra n.27; C. Matthew Schulz, Recruiting

& retaining the best & brightest talent, L.A. DAILY J. (Dec. 26,

2013).

30 Sophia Kerby & Crosby Burns, The Top 10 Economic

Facts of Diversity in the Workplace, CTR. FOR AM. PROGRESS

(July 12, 2012), www.americanprogress.org/issues/labor/news/20

12/07/12/11900/the-top-10-economic-facts-of-diversity-in-the-

workplace; see also Blazovich, supra n.21, at 8-9.

>

Caucasian men.”3! Of those gay and lesbian profes-

sionals who left, “almost half... said that if their em-

ployer offered more or better benefits they would

have very likely stayed at their job.”32

LGBT equality also matters to heterosexual em-

ployees. In a 2010 poll, sixty-six percent of non-LGBT

respondents found it important that an employer of-

fer equal health insurance benefits to LGBT co-

workers.*%

States that refuse to allow or recognize same-sex

marriages require businesses that regularly deal with

state marital benefits (like amici) to single out col-

31 ~=Level Playing Field Inst., The Corporate Leavers

Survey: The Cost of Employee Turnover Due Solely to Unfairness

in the Workplace, 4 (2007), www.lpfi.org/sites/default/files/corpor

ate-leavers-survey.pdf.

32 Id. at 1; see also Williams Institute, supra n.20, at 17

(“{Rlespondents who perceived more workplace discrimination

reported significantly lower levels of job commitment and

significantly higher levels of turnover intentions. [Other studies]

found a similar relationship between discrimination and job

commitment or turnover intentions.”); Belle R. Ragins, et al,

Making the Invisible Visible: Fear and Disclosure of Sexual

Orientation at Work, 92 J. APPLIED PSYCHOL. 1103, 1114 (2007)

(study showing that LGBT employees who feared negative

consequences to disclosure of their sexual orientation reported

greater turnover intentions and less organizational

commitment); Scott B. Button, Organizational Efforts to Affirm

Sexual Diversity: A Cross-Level Examination, 86 J. APPLIED

PSYCHOL. 17, 23 (2001) (“[RJesults demonstrated that treatment

discrimination toward sexual minorities was associated

negatively with the job satisfaction ... and organizational

commitment ... of lesbian and gay employees.”).

33) = Out & Equal, supra n.28.

2.

leagues with same-sex partners or registered domes-

tic partnerships for separate and unequal treatment,

as compared to employees with different-sex part-

ners. These state mandates upset our business phi-

losophy and prevent employers like amici from reach-

ing their full economic potential by discouraging

highly-qualified employees from living and working

in all of the jurisdictions where we do, or want to do,

business.

&. Employees in same-sex relation-

ships receive varying, if any, access

to the rights, benefits, and privileg-

es that different-sex couples enjoy.

Marriage equality is a reality in most of the Unit-

ed States right now. After Windsor, the federal gov-

ernment now recognizes all couples “whom the State,

by its marriage laws, sought to protect in personhood

and dignity” as married.* In the absence of a control-

ling statute to the contrary, the federal government

respects same-sex couples as lawfully married if their

marriages were performed in a state that legally au-

thorizes such marriages.*5

3% =6©6 Windsor, 133 S. Ct. at 2696.

36 Spousal eligibility for veteran’s benefits and Social Secu-

rity benefits turns on marital status under the laws of a couple’s

state of residence rather than the laws of the state in which

their marriage was celebrated. See 38 U.S.C. § 103(c); 42 U.S.C.

§ 416(h)(1)(A)G). Same-sex couples whose lawful marriages are

not recognized by the state in which they live are thus ineligible

for such benefits. These provisions are currently the subject of

litigation. See Murphy v. Colvin, No. 1:14-cv-01764 (D.D.C. Oct.

22, 2014) (stayed) (challenging social security eligibility provi-

_ 28 -

While “marriage is more than a routine classifica-

tion for purposes of certain statutory benefits,”°6 as a

legal status, marriage touches numerous aspects of

life, both practical and profound.’ Federal and state

law provide the working family many benefits and

protections relating to health care, dependent care,

protected leave, and retirement. These laws provide

security and support to an employee grappling with

sickness, disability, childcare, family crises, or re-

tirement—allowing the employee to devote more fo-

cus and attention to his or her work.

Those states that still prohibit same-sex marriage

deny gay and lesbian employees in committed rela-

tionships equal access to government-afforded rights

and benefits. This can result in same-sex couples be-

ing denied spousal rights most Americans take for

granted, including adoption and parental rights, as

well as the right to make medical decisions for an in-

capacitated spouse, access to health insurance and

retirement benefits, property protections, and inher-

sions); Taylor v. Brasuell, No. 1:14-cv-00273 (D. Idaho July 7,

2014) (challenging veteran’s benefits eligibility provision).

3% =6Windsor, 133 S. Ct. at 2692.

37 = Kitchen, 755 F.3d at 1215 (statutes restricting marriage

between same-sex couples “bring[] financial harm to children of

same-sex couples ... [,] raise[] the cost of health care for families

by taxing health benefits provided by employers to their work-

ers’ same-sex spouses’ and ‘den[y] or reduce[] benefits allowed to

families upon the loss of a spouse and parent, benefits that are

an integral part of family security”) (quoting Windsor, 133 S. Ct.

at 2695).

. 29.

itance.** In Alabama, for example, a same-sex spouse

(even if legally married in other parts of the country)

cannot adopt his or her spouse’s children—unless the

birth parent relinquishes all parental rights to his or

her child before the adoption occurs.%9

In addition to basic state benefits appurtenant to

marriage, state bans on same-sex marriage also pre-

vent same-sex couples from receiving myriad federal

benefits, such as those relating to health insurance,

military benefits, taxes, and immigration law.*° The

U.S. Department of Justice, for example, has an-

nounced that same-sex married couples will receive

equal federal death benefits and educational pay-

ments for federal public safety officers, equal victim

compensation payments, equal treatment in bank-

ruptcy cases, equal rights for inmates in federal pris-

on, and equal access to the marital privilege in feder-

al court.*!

38 Evan Wolfson, Protections Denied to Same-sex Couples &

Their Kids, FREEDOM TO MARRY, www.freedomtomarry.org/page

s/from-why-marriage-matters-appendix-b-by-evan-wolfson.

39 = See, e.g., In re Adoption of K.R.S., 109 So. 3d 176, 177

n.1 (Ala. Civ. App. 2012).

40 See Hon. Eric H. Holder, Jr., U.S. Att’y Gen., Remarks at

the Human Rights Campaign Greater N.Y. Gala (Feb. 10,

2014), www.justice.gov/iso/opa/ag/speeches/20 14/ag-speech-

140210.htm!] (discussing the extension of certain benefits to fed-

eral employees in same-sex marriages and their families).

41 Jd.; see also Matt Apuzzo, More Federal Privileges to Ex-

tend to Same-Sex Couples, N.Y. TIMES (Feb. 8,

2014), www.nytimes.com/2014/02/09/us/more-federal-privileges-

to-extend-to-same-sex-couples. html.

= 30) -

Same-sex couples living in a non-recognition state

must wed elsewhere in order to access federal bene-

fits.42 Even then, those same couples—and legally

married same-sex couples who later move to one of

those states (other than Missouri‘**)—will still be de-

nied access to the wide range of state benefits, mutu-

al responsibilities, and parental rights available to

married partners of different sexes. That bar not only

works to the detriment of employees, but also to em-

ployers that seek to recruit and retain the best hu-

man capital.

2. Marriage discrimination drives tal-

ented individuals away from juris-

dictions in which amici do business.

LGBT-friendly policies offer tangible advantages

in employee recruitment and retention.*4 Given the

powerful evidence above, amici can only conclude

that they are distinctly disadvantaged when looking

to hire qualified, talented personnel in the states that

do not allow same-sex couples to marry, or in asking

current personnel to relocate to such states.45 Job

42, The U.S. Government Accountability Office identified

1,138 rights, benefits, and privileges under federal law depend-

ent on marital status. U.S. Gen. Accounting Office, GAO-04-

353R, Defense of Marriage Act: Update to Prior Report (Jan. 23,

2004), www.gao.gov/assets/100/92441.pdf.

43 = See supra n.8.

44 ~=Blazovich, supra n.21, at 7-8.

46 In a 2014 poll, seventy-three percent of gay and lesbian

respondents said they would prefer a job with an employer in a

state where same-sex marriages are recognized and forty-two

percent said they would consider changing jobs if their employer

= -

candidates married to same-sex spouses may be un-

derstandably reluctant to pursue job opportunities in

states where their pre-existing marriages will not be

recognized, and where they can expect to lose access

to certain previously-enjoyed state-level benefits. +6

Single gays and lesbians may decide that the option

of a future legally-recognized marriage is enough to

justify passing up employment opportunities in states

with laws hostile to same-sex marriage.

Heterosexual individuals, too, may decide that

states hostile to marriage equality are not states

where they want to live and work.*’ Richard Florida,

a leading urban studies theorist, states that “mem-

required them to transfer to a state where same sex marriages

were not recognized. See Most Americans Say Employers Should

Never Discriminate, Even on Religious Grounds, According to

Latest Harris/Out & Equal Poll, OUT & EQUAL (Oct. 30, 2014),

www.harrisinteractive.com/NewsRoom/HarrisPolls/tabid/447/ctl/

ReadCustom%20Default/mid/1508/ArticleId/1514/Default.aspx.

46 Moving to a state that does not recognize same-sex

marriages may even imperil preexisting parental rights over the

children of same-sex couples. See, e.g., In re Seb C-M, NYLJ

1202640527093, at *1, 4 (N.Y. Surr. Ct. Jan. 6, 2014) (redacted

by court) (denying adoption application of same-sex spouse

because the non-birth mother already appeared on her child’s

birth certificate, but acknowledging that other jurisdictions may

not, based on the birth certificate alone, recognize petitioner's

parental status).

47 Matt Motyl, et al, How Ideological Migration

Geographically Segregates Groups, 51 J. EXPERIMENTAL SOC.

PSYCHOL. 1 (2014), www.researchgate.net/publication/25492998

2_How_IdeologicalMigration_Geographically_Segregates_and_P

olarizes_Groups/file/60b7d52efea63cb4b3.pdf (individuals are

moving from ideologically unfriendly communities to congruent

communities).

=~ &

bers of the creative class—roughly 50 million people

including scientists engineers, and entrepreneurs, re-

searchers and academics, architects and designers,

artists, entertainers and professionals in business,

media, management, healthcare and law” use diversi-

ty as a proxy for determining whether a city would

provide a welcoming home.** The Williams Institute

found that “creative-class” Massachusetts residents

in same-sex relationships were 2.5 times more likely

to have moved there in the three years after marriage

equality than in the three years before.*9

Before Windsor, representatives from Goldman

Sachs and Citigroup each described problems faced

by companies in dealing with the then-operative im-

migration system that made it difficult for same-sex

partners to immigrate.®° A Citigroup executive noted

that the hurdles posed “significant costs for compa-

nies that ha[d] to move workers out of the U.S. or in

lost productivity from dealing with an employee’s or

partner’s immigration status,” while a member of

Goldman Sachs’ management committee explained

* Human Rights Campaign, 2014 Municipal Equality In-

dex: A Nationwide Evaluation of Municipal Law,6 (2014),

www.hrc-assets.s3-website-us-east—1.amazonaws.com//files/

assets/resources/MEI-2014.pdf.

49 =6Gury J. Gates, Williams Inst., UCLA School of Law,

Marriage Equality & the Creative Class, 1—2, 4 (May 2009),

www.williamsinstitute.law.ucla.edu/wp-content/uploads/Gates-

MA-Creative-Class-May-2009. pdf.

50 Michael J. Moore, Same Sex Marriage Rules Hamper

Wall Street’s Recruiting, BLOOMBERG Bus. (Apr. 30,

2013), www.bloomberg.com/apps/news? pid=conewsstory &tkr=10

0OL: US&sid=a.hYJ30Xi7Vvo.

_ 33-

that restrictions on same-sex marriage made it more

difficult to attract and retain employees in same-sex

relationships who have spouses without United

States permanent residency.®! Similarly, a 2013 sur-

vey by the American Council on International Per-

sonnel reported that forty-two percent of responding

member organizations lost potential hires because

same-sex partners were at that time excluded from

immigration benefits; respondents also reported that

they could not complete internal transfers, even at

the executive level, for the same reason.5? The same

logic holds true for employee transfers and migration

across states. Employees with same-sex spouses face

similar costs and lost productivity when facing the

prospect being hired or transferring into non-

recognition states. As more states provide access to

marriage on equal terms, lesbian and gay employees

are less willing to live and work in states that do not,

to the detriment of their employers or would-be em-

ployers.

Such consequences have been observed across the

country. For example, the former Rector of The Col-

lege of William and Mary’s Board of Visitors lament-

ed the talent-retention problems caused by Virginia’s

(since-overturned) marriage ban:

os

62 Out on the Street & Immigration Equality, Thinking

Outside of the Closet: The Cost of LGBT Exclusion; How Discrim

inatory Immigration Laws Hurt Business, 9-10 (Feb. 5, 2013),

www.outleadership.org/wp-content/uploads/2013/11/Thinking-

Outside-the-Closet-Volume-2.pdf.

_34-

We already have lost valued gay and

lesbian faculty to our competitors who

do not discriminate. With changes in

federal benefits soon available to legally

married gay couples, we will lose more.

Two able individuals told me [recently]

that they are leaving for another state—

one a top professor [in a_ science-

technology field] and another a univer-

sity administrator just recruited to Vir-

ginia a few years ago.®

Indeed, Virginia’s governor lauded the initial fed-

eral district court decision overturning his state’s ban

on same-sex marriage, noting the Commonwealth

needed to ensure equality “to grow [Virginia’s] econ-

omy and attract the best businesses, entrepreneurs,

and families.”54 But the problem persists in states

63 Nick Anderson, Outgoing rector warns Virginia on gay

marriage, WASH. POsT (Aug. 12, 2013),

www.washingtonpost.com/lifestyle/magazine/outgoing-rector-

warns-virginia-on-gay-marriage/2013/08/1 2/d250d466-e956-

11e2-a301-ea5a8116d211_story.html; see also Marian Moser

Jones, Will Same-Sex-Marriage Rulings Lead to an LGBT

Brain Drain in Some States?, CHRON. HIGHER EDUC. (June 27, 2

013), (another professor has commented that “[w]hile a desire to

live full time with my spouse was the main motivator in my

move from a college in Virginia to one in Maryland, the antigay

legal environment in Virginia did play a role in my job

change”), www.chronicle.com/blogs/conversation/2013/06/27/will-

same-sex-marriage-rulings-lead-to-an-lgbt-brain-drain-in-some-

states/.

54 Governor Terry McAuliffe, Governor McAuliffe State-

ment on Bostic v. Rainey Ruling (Feb. 14, 2014), www.governor.

virginia.gov/news/newsarticle?articleId=3302 (discussing 970 F.

Supp. 2d 456 (E.D. Va. 2014)).

a, *

like Michigan, where immediately after the State

eliminated domestic partnership benefits for public

employees, college professors “started applying for

jobs at universities with comprehensive domestic

partnership benefits.”55

This evidence suggests that gay and lesbian em-

ployees may decide to leave a state hostile to same-

sex marriage for ones in which they can receive full

federal and state benefits—whether they are single

and wishing to marry, married out-of-state and desir-

ing equal access to state and federal benefits, or

simply motivated by the need for certainty in their

own life planning. Likewise, facing a possible transfer

into one of these states, talented individuals may

choose to part ways with their employers rather than

risk the detrimental effects of non-recognition on

themselves and their families. Other gay and lesbian

workers may seek certainty and forego employment

opportunities in these states altogether.

C. Marriage Discrimination Injures Amici’s

Businesses.

By not permitting same-sex couples to marry,

states impose significant administrative burdens on

businesses. Although amici can, and often do, volun-

tarily attempt to lessen the financial inequality

placed on employees, those workarounds impose ad-

ditional and unnecessary business expense, while

still not fully ameliorating the differential treatment

of employees. And the combined burden of adminis-

trative costs and tax consequences is significant; the

55 Broken Bargain, supra n.14, at 67.

- 36-

2015 estimated cost of marriage inequality to the pri-

vate sector is $1.3 billion.®®

2. The states’ bans impose significant

burdens on our employees and our

businesses.

For employers, the patchwork of inconsistent state

law creates significant burdens in the administration

of benefits for employees whose marriages are not

recognized by the state. For example, “[i]n [non-

recognition states], employers are still expected to

impute income spent on benefits provided to a same-

sex spouse for state tax purposes, but not to do so for

federal tax purposes....”57 The situation is complicat-

ed further when mobile employees live, work, file

taxes, and receive benefits in multiple jurisdictions.

Georgia’s tax code is a good example. Although the

federal tax code now recognizes valid marriages be-

tween same-sex couples, Georgia’s Constitution

states that “[nJo union between persons of the same

sex shall be recognized by this state as entitled to the

benefits of marriage.”®® According to Georgia’s De-

partment of Revenue, that means that same-sex mar-

ried couples must file state tax returns separately, as

single status filers or, if qualified, as head-of-

56 Kopansky & Cacciotti, supra n.9, at 1.

57 Joanne Sammer & Stephen Miller, The Future of Domes-

tic Partner Benefits: If same-sex couples can wed, should employ-

ers provide benefits to unmarried partners?, SOC’Y FOR HUM.

RES. MGnT. (Oct. 21, 2013), www.shrm.org/hrdisciplines/benefit

s/articles/pages/domestic-partner-benefits.aspx.

58 GA. CONST. art. I, § 4, para. 1(b).

= -

household status filers.59In light of this and similar

laws, employers must (i) identify from among their

married employees those married to a spouse of the

same sex; (ii) treat an employee with a same-sex

spouse as unmarried for state tax purposes; (iii) treat

the same employee as married for federal tax purpos-

es; and (iv) monitor every such employee’s state of

residence and alter the treatment of their tax liability

whenever the employee moves from a non-recognition

state to a recognition state or vice versa. These mul-

tiple, continual, and mandatory obligations result in

significant burdens and expenses.

Discriminatory state laws add another dimension

of problems for businesses. Human resources de-

partments are often the first stop for employees con-

fused about conflicting legal rules. That means bene-

fits administrators may be asked to give advice and

make recommendations about complex legal issues.

Even the well informed human resources professional

faces the challenge of addressing inconsistent state

laws. And a mistaken answer may lead to harsh tax

and financial consequences for the employee, and fur-

ther erosion of workplace morale.

These concerns are more pronounced today than

ever before given the mobile nature of the modern

workforce. Employees often work in several states,

where they must then file taxes and determine their

59 Ga. Dep’t of Revenue, Informational Bulletin No. IT-

2013-10-25 U.S. Supreme Court & the Defense of Marriage Act

3 (Oct. 25, 2013), www.dor.georgia.gov/sites/dor.georgia.gov/files

/related_files/document/LATP/Bulletin/DOMA_bulletin_10-25-

2013_1.pdf.

_ 38 -

eligibility for various state benefits.©° This creates

significant administrative burdens on employers who

must keep up with the rapidly changing legal land-

scape, and then create and maintain complicated eq-

uitable policies and benefits.

Companies operating nationwide, many of whom

have centralized HR functions, find themselves in a

complicated labyrinth of differing rules, regulations,

and internal policies. These variations must often be

incorporated manually into otherwise automated pro-

cesses, a requirement that is both burdensome and

prone to human error. The burden on small employ-

ers may be particularly onerous, as they may find it

difficult to devote limited resources to navigating con-

flicting and changing laws, let alone to establishing

workarounds. Benefits administration for an employ-

ee with a same-sex partner is more likely to occur in

an ad hoc, piecemeal fashion, increasing the potential

for error and disparate treatment. Establishing mar-

riage equality nationwide would result in benefits

and tax treatment that can be more efficiently and

equitably administered.

In an attempt to alleviate the disparities and frus-

trations of discriminatory benefit systems and other

benefits-related matters, some employers have de-

termined that it is in their business interests to incur

the cost and administrative burden of “workarounds.”

These employer-created benefits structures attempt

to compensate for the lack of recognized relationship

60 See, e.g., RICHARD FLORIDA, THE RISE OF THE CREATIVE

CLASS—REVISITED 262 (2d ed. 2012) (“[S}kills and skilled people

are an incredibly mobile factor of production; they flow.”).

~~ =

status for employees who cannot marry under state

law, and to provide benefits for those whose marriag-

es are recognized at the federal, but not the state,

level.

To take one common example, workers in a non-

recognition state with a same-sex spouse or partner

are typically taxed on the value of health-care bene-

fits for their spouses/partners, whereas employees

with different-sex spouses are not so taxed. Many

employers will attempt to address such taxability dif-

ferences by increasing (or “grossing up”) pay for

workers with same-sex spouses/partners. ®! While

grossing up and other workarounds offer many em-

ployers a way to reduce the competitive disadvantage

of doing business in states that ban same-sex mar-

riage, they also increase costs on the employer be-

yond the direct cost of benefits.®

The U.S. Office of Personnel Management noted

that the grossing-up approach “raises costs consider-

ably .... Under a grossing up policy, a $1,000 net cash

61 Broken Bargain, supra n.14, at 72—93; Human Rights

Campaign, Domestic Partner Benefits: Grossing

Up to Offset Imputed Income Tax, www.hrc.org/resources/entry/

domestic-partner-benefits-grossing-up-to-offset-imputed-income-

tax; Tara Siegel Bernard, A Progress Report on Gay Employee

Health Benefits, N.Y. TIMES (updated Mar. 4, 2013),

www.bucks.blogs.nytimes.com/2010/12/14/a-progress-report-on-

gay-employee-health-benefits/.

62 U.S. Office of Personnel Mgmt., Grossing Up Awards,

Why & Why Not, www.opm.gov/policy-data-

oversight/performance-management/performance-management-

cycle/rewarding/grossing-up-awards/.

- 40 -

award would actually cost the agency $1,712.80.” © It

is estimated that grossing up for an employee who

incurred between $1,200 and $1,500 in extra taxes

costs the employer between $2,000 and $2,500. In

other words, employers with a grossing up policy pay

more to provide equivalent benefits.

Grossing up is a complicated process for employ-

ers, requiring careful consideration of such things as

appropriate tax rates, coverage for dependents or a

partner’s children, and the impact of marital status.®

After the Windsor decision, state-level tax decisions

regarding individuals with same-sex spouses now “af-

fect not only gross-up calculations for these employ-

ees, but also the taxability for state purposes of bene-

fits made available to spouses of employees married

to a person of the same sex.”®* [In addition, worka-

68 Id.

64 Bernard, supra n.61.

65 For an overview of the complexities of grossing-up, see,

e.g., Todd A. Solomon & Brian J. Tiemann, Issues to Consider in

Providing a Tax Gross-Up for Employers Covering Same-Sex

Spouses and Partners under the Employer's Medical, Dental,

and Vision Plans, 4 (No. 2) BLOOMBERG L. REPORTS—

EMPLOYEE BENEFITS (2011), www.mwe.com/info/pubs/solomon_t

iemann_tax_gross-up_for_employees.pdf; see also Todd A.

Solomon & Brett R. Johnson, Walking Employers Through the

Regulatory Maze Surrounding Same-Sex Domestic Partner

Benefits, PROBATE & PROPERTY 14 (Mar/Apr. 2012),

www.americanbar.org/content/dam/aba/publications/probate_pro

perty_magazine/v26/02/2012_aba_rpte_pp _v26_2 mar apr_solo

mon_johnson.authcheckdam.pdf.

66 Peter K. Scott, State Positions on Same-Sex Married

Couple Filing Status Will Affect Employers, Worldwide

ERC® (Feb. 3, 2014), www.worldwideerc.org/Blogs/Mobility Law

a.

rounds can raise concerns about complexity in provid-

ing and administering domestic partner benefits, and

potential legal liabilities.*

In short, workarounds themselves cause adminis-

trative burden, sometimes requiring employers with

grossing up policies to retain experts to craft policies

and structure systems that will account for gross-up

amounts, as well as to educate human resources,

benefits, and payroll administrators. And these

workarounds may also attract attention from regula-

tors or cause tension with certain employees, share-

holders, or investors due to the administrative bur-

dens and increased costs.

Amici and other employers incur a real cost to ac-

count for and respond to unequal access to marriage

across the United States, a cost to the American pri-

vate sector estimated at $3.5 million per day. ®

Granting same-sex couples equal access to marriage

would remove significant financial and regulatory

burdens currently imposed on American employers.

2. State bans undermine our corporate

cultures.

The denial of marriage rights to same-sex couples

in non-recognition states goes against our core values

Blog/Lists/Posts/Post.aspx?List=c020ace5%2D48ad%2D47b2%2

D8295%2Da4cf7 lba9e34&ID=192.

87 See Li & Nagar, supra n.17, at 531 (discussing some of

the challenges an employer could face in maintaining a same-

sex domestic partnership benefit policy).

686 Kopansky & Cacciotti, supra n.9, at 2.

4.

and principles. As employers, we recognize the value

of diversity, and we want the jurisdictions where we

operate to recognize the need to enable all married

persons to “live with pride in themselves and their

union[s],”®° and to honor the “personal dignity and

autonomy” of all of our employees.7°

We develop and implement non-discrimination

policies not only because they are the right thing to

do, but also because these policies are crucial to our

ability to recruit and retain excellent employees. The

ability to hire the best human capital helps amici

create teams and corporate cultures that allow us to

create and innovate, and ultimately increase our prof-

its and economic value. Marriage bans conscript em-

ployers, as the administrators of benefits, to imple-

ment laws that treat employees in committed same-

sex relationships differently from employees married

to different-sex spouses. The need to accommodate

state laws hostile to same-sex marriage prevents em-

ployers from treating similarly situated employees

identically, our stated policies notwithstanding.

Our employees are our most valuable assets—and

yet the law treats many of them as second-class citi-

zens. The reality is that even “small differences in

how people are treated... convey strong messages

about the[ir] perceived relative value.””!

68 Windsor, 133 S. Ct at 2689.

70 Kitchen, 755 F.3d at 1218 (quoting Lawrence v. Texas,

539 U.S. 558, 574 (2003)).

71 ~©Sears, et al., supra n.19, at 6.

~43.

An organization’s policies toward its

employees, whether an _ inclusive

healthcare policy or a discriminatory

promotion and hiring policy, send latent

signals to the entire organization re-

garding permissible biological and be-

havioral attributes. Such signals may

then impact all employees, affecting

their comfort, their unconscious projec-

tions of identity and gender in critical

interpersonal meetings. 72

The end result is employee uncertainty, low morale,

decreased productivity, and increased costs.

Diversity provides many benefits, but must be

well-managed within each organization.73 In 2011, an

interview study presented substantial anecdotal evi-

dence that perceptions of inequality in a workforce

can lead to high turnover, loss of talented employees,

litigation, and bad publicity.74 Even if we take on the

burden of developing workarounds to ameliorate dis-

parate state treatment, we are still placed in the role

72 «6Li & Nagar, supra n.17, at 543 (internal citations omit-

ted) (emphasis in original).

73 U.K. Gov't Equalities Office, Dep’t for Bus. Innovation &

Skills, The Business Case for Equality and Diversity: A survey of

the academic literature, BIS OCCASIONAL PAPER No. 4, vi, 27, 28

(Jan. 2013), www.gov.uk/government/uploads/system/uploads/at

tachment_data/file/49638/the_business_case_for_equality_and_

diversity.pdf.

7% =©6 Jd. at 7 (citing Mustafa F. Ozbilgin & Ahu Tatli, Map-

ping out the field of equality and diversity: rise of individualism

and voluntarism, 64 HUM. RELATIONS 1229-53 (2011)).

- 44 -

of intrusive inquisitor, imputer of taxable income,

and administrator of legally-mandated separate and

unequal systems. For employees who report them-

selves as married, we must determine the sex of their

spouse and judge whether that marriage is recog-

nized for state law purposes where the employee lives

and works. That the law requires us to even ask such

questions emphasizes that those employees are in the

“unstable position of being in a second-tier mar-

riage.”75 Such judgments may unintentionally rein-

force the State’s message that these employees and

their relationships are not “worthy of dignity in the

community equal with all other marriages.”76

As a result, we are hampered in our ability to

make our businesses as diverse and inclusive as pos-

sible, despite our stated policies and our recognized

business case. We become, in short, party to our em-

ployees’ injury—and our own.

CONCLUSION

Employees with partners of the same sex

should be permitted to marry if they so choose, and

then should be treated identically to their married

heterosexual counterparts. State laws that require

otherwise impose a significant burden on us and

harm our ability to attract and retain the best em-

ployees. Such laws force businesses to uphold dis-

criminatory laws that run counter to important cor-

porate values. In the end, economic growth suffers.

75 Windsor, 133 S. Ct. at 2694.

7% =I d. at 2692.

+

The decision before the Court perpetuates that harm,

and amici respectfully urge that the judgment of the

Court of Appeals be reversed.

March 5, 2015

Respectfully submitted,

SUSAN BAKER MANNING

Counsel of Record

MICHAEL L. WHITLOCK

AMANDA D. SMITH

JOHN A. POLITO

JAWAD MUADDI

RACHEL L. STRONG

CAROL E. HEAD

KIMBERLEY E. LUNETTA

STEPHANIE SCHUSTER

SARA M. CARIAN

JACQUELYNNE M. HAMILTON

MORGAN, LEWIS & BOcKIUS LLI

2020 K Street N.W.

Washington, D.C. 20006

(202) 373-6000

susan.manning@morganlewis.con

MEGHAN RHEA

WG+R LAw Group, P.C.

2233 Santa Clara Avenue

Alameda, California 94501

(510) 323-4034

APPENDIX

APPENDIX A:

IDENTIFICATION OF AMICI

A. L. Nella & Company, LLP, CPAs is an account-

ing firm based in San Francisco, California.

A.T. Kearney is a leading global management con-

sulting firm with offices in more than 40 countries.

Since 1926, we have been trusted advisors to the

world’s foremost organizations. A.T. Kearney is a

partner-owned firm, committed to helping clients

achieve immediate impact and growing advantage on

their most mission critical issues.

Aardema Whitelaw, PLLC is a full-service insur-

ance defense law firm with a prime focus on defend-

ing physicians, hospitals, and allied health profes-

sionals in complex medical malpractice litigation

throughout the state of Michigan.

Acacia Home LLC is a modern home goods store in

San Francisco, CA that focuses on independent de-

signers and select smaller brands.

Accenture is a global management consulting, tech-

nology services and outsourcing company, with more

than 319,000 people serving clients in more than 120

countries. Combining experience, comprehensive ca-

pabilities across all industries and business func-

tions, and extensive research on the world’s most suc-

cessful companies, Accenture collaborates with cli-

ents to help them become high-performance busi-

nesses and governments.

Aetna Inc. is one of the nation’s leading diversified

health care benefits companies offering a broad range

- App 2-

of traditional, voluntary and consumer-directed

health insurance products and related services to ap-

proximately 37.3 million people. Aetna is a publicly

traded corporation based in Hartford, Connecticut

with over 35,000 employees across the U.S. and

worldwide.

Air Products and Chemicals, Inc., headquartered

in Allentown, Pennsylvania, and employing over

20,000 employees in 50 countries, is a leading indus-

trial gases company which provides atmospheric, pro-

cess and specialty gases, and related equipment to

manufacturing markets including metals, food and

beverage, refining and petrochemical, and natural

gas liquefaction. Air Products’ materials technologies

segment serves the semiconductor, polyurethanes,

cleaning and coatings, and adhesives industries.

AJ Leo Electric and Solar is an electrical and solar

business located in Michigan.

Akamai Technologies, Inc. is an Internet content

delivery network headquartered in Cambridge, Mas-

sachusetts. Akamai employees 5,000 people world-

wide.

Alaska Airlines, together with its partner regional

airlines, serves 95 cities through an expansive net-

work in Alaska, the Lower 48, Hawaii, Canada and

Mexico.

Alcoa Inc. is a global leader in lightweight metals

engineering and manufacturing. Alcoa pioneered the

aluminum industry over 125 years ago, and today,

our approximately 60,000 people in 30 countries de-

- App 3 -

liver value-add products made of titanium, nickel and

aluminum, and produce best-in-class bauxite, alumi-

na and primary aluminum products.

Amazon Services Inc. is a commercial printing

company, established in 1987, and is currently certi-

fied as a woman-owned, SBE/MBE minority compa-

ny. Amazon Printers serves elite accounts in market-

ing, procurement and commercial accounts in the US,

Caribbean and South America, creating award win-

ning pieces and custom made items.

Amazon.com, Inc., based in Seattle, Washington, is

one of the world’s largest and best known online re-

tailers. Amazon seeks to be the Earth’s most custom-

er-centric company, where customers can discover

anything they might want to buy online at the lowest

possible prices.

American Airlines Group Inc. is the holding com-

pany for American Airlines and US Airways. Togeth-

er with wholly owned and third-party regional carri-

ers operating as American Eagle and US Airways

Express, the airlines operate an average of nearly

6,700 flights per day to 339 destinations in 54 coun-

tries from its hubs in Charlotte, Chicago, Dallas/Fort

Vv orth, Los Angeles, Miami, New York, Philadelphia,

Phoenix and Washington, D.C.

American Apparel is a leading basics brand for

young adults and people of all ages, with both whole-

sale and retail divisions globally. Knitting, dyeing,

sewing, photography, marketing, distribution, and

design all happen in our Los Angeles facilities.

- App 4-

American Express Company is a global services

company, providing customers with access to prod-

ucts, insights and experiences that enrich lives and

build business success.

American International Group, Inc. (AIG) is a

leading international insurance organization head-

quartered in New York City serving customers in

more than 130 countries and jurisdictions. AIG com-

panies serve commercial, institutional, and individual

customers with property-casualty, life insurance and

retirement services.

Aparicio-Mercado Law, L.C. is a Los Angeles, Cal-

ifornia law firm that handles discrimination and

wage and hour issues.

Apple Inc. is a multinational consumer electronics

and software company based in Cupertino, California.

Apple employs over 90,000 people across the U.S. and

worldwide.

AppNexus Inc. is a technology company that pro-

vides trading solutions and powers marketplaces for

Internet advertising. Headquartered in New York

City with 22 global offices, AppNexus employs more

than 800 professionals.

Aramark, headquartered in Philadelphia, Pennsyl-

vania, is a global leader in food, facilities manage-

ment and uniforms with 270,000 employees in 22

countries.

Arbor Brewing Company, LLC is a privately

owned brewpub and microbrewery in Michigan that

- App 5 -

employees 100 people and distributes its beer in three

states.

Arnold & Porter LLP is an international law firm

that employs over 800 lawyers with U.S. offices in

Washington, D.C., California, New York, Colorado,

and Texas.

Aspen Skiing Company owns and operates four ski

mountains, two hotels and 18 restaurants in the As-

pen and Snowmass areas of Colorado, and employs

3,400 people in winter.

Assemble Sound LLC, headquartered in Detroit,

Michigan, is an artist-driven initiative to more effec-

tively connect Detroit musicians to each other and

our work to the broader music-loving world.

AT&T Inc. helps millions of people and businesses

around the globe stay connected through leading

wireless, high-speed Internet, voice and cloud-based

services. AT&T helps people mobilize their worlds

with state-of-the-art communications, entertainment

and video services, and amazing innovations like

connected cars and devices for homes, offices and

points in between.

Atlas Cut Stone, headquartered in Oak Park, Mich-

igan and founded in 1935, specializes in natural stone

products for creative concepts, design and localiza-

tion. Atlas works with homeowners, builders, and

highly specialized architectural firms.

App 6 -

Atticus Circle is a non-profit organization com-

prised of straight allies standing up for equal rights

for LGBT citizens and their families.

The Austin Gay & Lesbian Chamber of Com-

merce’s mission is to cultivate, promote and empow-

er the economic well-being of the LGBT business

community and their allies through collaboration,

education and community development.

Avanade Inc. helps customers realize results in a

digital world through business technology solutions,

cloud and managed services. Avanade, which is ma-

jority owned by Accenture, was founded in 2000 by

Accenture LLP and Microsoft Corporation and has

23,000 professionals in more than 20 countries.

Bain & Company, Inc. is a leading global strategy

consulting firm, headquartered in Boston, Massachu-

setts, with over 5,500 staff based in 50 offices around

the world.

Bakehouse Art Complex, located in Miami, Flori-

da, provides affordable studio spaces, exhibition op-

portunities, educational and artist advancement pro-

gramming, and common work spaces for emerging

and mid-career artists.

Baker & McKenzie LLP is a global law firm of

4,200 lawyers in 47 countries, including offices in

New York and California.

Bank of America is one of the world’s largest finan-

cial institutions, serving individual consumers, small-

and middle-market businesses, institutional inves-

- App 7 -

tors, large corporations and governméats with a full

range of banking, investing, asset management and

other financial and risk management products and

services. Bank of America employs more than

223,000 people worldwide operating in all 50 states,

the District of Columbia, Puerto Rico, the U.S. Virgin

Islands and over 35 countries.

The Bank of New York Mellon Corporation

(BNY Mellon), headquartered in New York, is a lead-

ing provider of investment management and invest-

ment services.

Barclays is an international financial services pro-

vider engaged in personal banking, credit cards, cor-

porate and investment banking and wealth manage-

ment with an extensive presence in Europe, the

Americas, Africa and Asia. With over 300 years of

history and expertise in banking, Barclays operates

in over 50 countries and employs approximately

140,000 people. Barclays moves, lends, invests and

protects money for customers and clients worldwide.

Barnes & Noble, Inc. is a leading retailer of con-

tent, digital media and educational products. The

Company operates 649 Barnes & Noble bookstores in

50 states, and one of the Web’s largest e-commerce

sites. Its NOOK digital business offers award-

winning NOOK® products and an expansive collec-

tion of digital reading and entertainment content

through the NOOK Store®, while Barnes & Noble

College Booksellers, LLC operates 714 bookstores

serving over five million students and faculty mem-

bers at colleges and universities across the United

States.

- App 8 -

bebe stores, inc. is a global specialty retailer, which

designs, develops and produces a distinctive line of

contemporary women’s apparel and accessories under

the bebe and BEBE SPORT brand names. bebe cur-

rently operates 168 bebe retail stores including the

on-line store bebe.com, and 35 bebe outlet stores in

the United States. Additionally bebe distributes bebe

branded product through its licensees in approxi-

mately 23 countries.

BD (Becton, Dickinson and Company) is a medi-

cal technology company that serves healthcare insti-

tutions, life science researchers, clinical laboratories,

industry and the general public. BD manufactures

and sells a broad range of medical supplies, devices,

laboratory equipment and diagnostic products. BD is

headquartered in the United States and has more

than 30,000 associates in 50 countries worldwide.

Belcampo Inc. was founded in 2011. Our companies

include Belcampo Farms where we humanely raise

our organic meat, our humane certified processing

facility Belcampo Butchery and Belcampo Meat Co.

which runs our Butcher Shops and Restaurants with

six locations in California.

Ben & Jerry’s is a leading manufacturer of super

premium ice cream, yogurt and sorbet distributed in

supermarkets, grocery stores, and Ben & Jerry’s

Scoop Shops in more than 35 countries around the

world.

Big Duck Studio, Inc. is a New York communica-

tions firm that works exclusively with nonprofits to

- App 9-

help reach supporters, build awareness, and raise

money.

Bigelow Villa LLC dba The Lobby Bar is located on

Capitol Hill in Seattle, Washington. We are a cocktail

lounge that caters to the diverse Seattle community.

Billy’s Farm is an organic Christmas tree farm lo-

cated in Wilton, California.

BlackRock, Inc. is a leader in investment manage-

ment, risk management and advisory services for in-

stitutional and retail clients worldwide. Headquar-

tered in New York City, as of December 31, 2014, the

firm had approximately 12,200 employees in more

than 30 countries and a major presence in key global

markets, including North and South America, Eu-

rope, Asia, Australia and the Middle East and Africa.

Bloomberg L.P. is a global business and financial

information and news leader. Bloomberg provides re-

al time financial information to more than 320,000

subscribers globally. Headquartered in New York,

Bloomberg employs more than 15,500 people in 192

locations around the world.

Blue Apron, Inc. makes home cooking accessible by

delivering original recipes and farm-fresh ingredients

to customers nationwide. Headquartered in New

York City, the company delivers over 1,000,000 meals

per month, and employs more than 1,100 people.

Blue Heron Ventures is an angel investment fund

and Japanese trading company based in California.

- App 10 -

Blue Moon Hotel / Winter Haven Hotel are two

South Beach Miami hotels that are part of Hersha

Hospitality Management.

Blume, Faulkner & Skeen, PLLC provides legal

services for all aspects of a business through media-

tion, litigation, or arbitration and also represents in-

dividuals and families at critical crossroads in life.

Boehringer Ingelheim Pharmaceuticals, Inc.,

based in Ridgefield, Connecticut, is the largest U.S.

subsidiary of Boehringer Ingelheim Corporation and

a member of the Boehringer Ingelheim group of com-

panies. The Boehringer Ingelheim group is one of the

world’s 20 leading pharmaceutical companies. Head-

quartered in Ingelheim, Germany, it operates global-

ly with 142 affiliates and more than 47,400 employ-

ees.

Boston Community Capital, Inc. is a Boston,

Massachusetts based community development finan-

cial institution that invests in affordable housing pro-

jects, and job creation in low-income communities.

The Boston Consulting Group (BCG) is a global

management consulting firm and a leading advisor

on business strategy.

The Boston Foundation is a corporation located in

Boston, Massachusetts that is one of the oldest and

largest community foundations in the nation. The

Foundation is a partner in philanthropy with some

1,000 separate charitable funds established by do-

nors, either for the general benefit of the community

or for special purposes.

- App 11 -

Boston Medical Center Corporation is a private,

not-for-profit, 482-bed academic medical center locat-

ed in Boston, Massachusetts, and is the largest pro-

vider of trauma and emergency services in New Eng-

land.

Boston Scientific Corporation transforms lives

through innovative medical solutions that improve

the health of patients worldwide. The company,

which has approximately 24,000 employees, is head-

quartered in Massachusetts and has operations in

multiple locations around the world.

Brady Mills LLC, headquartered in Nashville, Ten-

nessee, is a website development and online market-

ing company providing services to a variety of indus-

tries throughout the United States and abroad.

BrandQuery LLC is a branding, advertising and

marketing agency specializing in brand enhance-

ment. Our work is guided by client input, their exist-

ing brand(s), and research.

Bristol-Myers Squibb Company is a global phar-

maceutical company whose mission is to discover, de-

velop and deliver innovative medicines that help pa-

tients prevail over serious diseases.

Broadcom Corporation is a global leader and in-

novator in semiconductor solutions for wired and

wireless communications. Broadcom is headquartered

in Irvine, California with over 11,000 employees

across the U.S. and worldwide.

- App 12 -

Brocade networking solutions helps organizations

transition to a world where applications and infor-

mation reside anywhere. With headquarters in San

Jose, California and approximately 4,000 employees

worldwide, Brocade serves a wide range of industries

and customers in more than 160 countries.

Cablevision Systems Corporation is one of the

largest cable operators in the United States, provid-

ing digital cable television, high speed data and tele-

phone services to approximately 3 million customers

in the New York metropolitan area. Through its local

media and programming properties — News 12 Net-

works, Newsday Media Group and MSG Varsity —

Cablevision also delivers news and information creat-

ed specifically for the communities it serves.

Capital One Financial Corporation is one of the

top 10 banks in the country serving retail, small

business and commercial clients through a variety of

traditional and digital channels. Capital One has

banking locations across New York, New Jersey, Lou-

isiana, Texas, Virginia, Maryland and the District of

Columbia.

Captain Wendell’s Marine Services LLC is a full

service boat captain resource for boating education,

on the water instruction, and marine surveyor con-

sultation for recreational boaters in the Puget Sound

region.

Cardinal Health, Inc., headquartered in Dublin,

Ohio, is a health care services company that improves

the cost-effectiveness of health care. As the business

behind health care, Cardinal Health helps pharma-

- App 13 -

cies, hospitals, ambulatory surgery centers, clinical

laboratories and physician offices focus on patient

care while reducing costs, enhancing efficiency and

improving quality. Cardinal Health employs 34,000

people worldwide.

Care Resource provides HIV/AIDS research, pre-

vention, care and treatment services to individuals in

Florida’s Miami-Dade and Broward Counties.

CBS Corporation’s operations span the media and

entertainment industries and include a major televi-

sion network (CBS), television content production

and distribution, interactive businesses, motion pic-

tures, cable program services (including Showtime),

publishing (Simon & Schuster), television stations

and radio stations. CBS Corporation is headquar-

tered in New York City with approximately 17,300

salaried employees (as of 12/31/14) across the United

States and worldwide.

CEB, a leading member-based advisory company,

equips more than 10,000 organizations around the

globe with insights, tools and actionable solutions to

transform enterprise performance.

Central Physical Therapy & Fitness, PSC is an

outpatient physical therapy clinic in Seattle, Wash-

ington, providing individualized physical therapy

care and personal fitness training.

CGI, founded in 1976, is the fifth largest independent

information technology and business process services

firm in the world. Approximately 68,000 professionals

serve thousands of global clients from offices and de-

- App 14-

livery centers across the Americas, Europe and Asia

Pacific, leveraging a comprehensive portfolio of ser-

vices including high-end business and IT consulting,

systems integration, application development and

maintenance, infrastructure management as well as

a wide range of proprietary solutions.

Charlotte Business Guild’s mission is to integrate

business development, social action and leadership,

and to facilitate economic proliferation for the lesbi-

an, gay, bisexual and transgender (LGBT) community

and those who support equality for all. Together, we

will achieve this mission by increasing visibility

through professional networking and marketing,

maintaining operational sustainability, and strategic

training.

The Chubb Corporation is the holding company for

the property and casualty insurance companies re-

ferred to as the Chubb Group of Insurance Compa-

nies, which since 1882 have provided property and

casualty insurance to customers around the globe.

Headquartered in Warren, New Jersey, Chubb em-

ployees 10,200 employees worldwide.

CIGNA Corporation is a global health service com-

pany dedicated to helping people improve their

health, well-being and sense of security. All products

and services are provided exclusively by or through

operating subsidiaries of Cigna Corporation, includ-

ing Connecticut General Life Insurance Company,

Cigna Health and Life Insurance Company, Life In-

surance Company of North America and Cigna Life

Insurance Company of New York. Such products and

services include an integrated suite of health ser-

- App 15 -

vices, such as medical, dental, behavioral health,

pharmacy, vision, supplemental benefits, and other

related products including group life, accident and

disability insurance. Cigna maintains sales capability

in 30 countries and jurisdictions, and has more than

86 million customer relationships throughout the

world.

Cisco Systems, Inc. is a multinational networking

equipment and technology company headquartered in

San Jose, California. Cisco has over 70,000 employees

across the United States and worldwide.

Citigroup Inc., a leading global bank, provides con-

sumers, corporations, governments and institutions

with a broad range of financial products and services.

Headquartered in New York, Citi has over 240,000

employees worldwide and does business in more than

160 countries and jurisdictions.

City Catering Company is a full-service Seattle,

Washington caterer providing innovative food, bever-

age, decor and service.

City Lites Neon, Inc. is an electrical sign company

in Seattle, Washington, servicing, fabricating and in-

stalling all types of electrical signs.

The City of Ann Arbor, Michigan is located in

Southeastern Michigan. Founded as a town in 1824,

Ann Arbor is the county seat for Washtenaw County

and now has a population of 113,934.

Civitas Public Affairs Group delivers winning ad-

vocacy and public affairs campaigns for its clients

- App 16 -

and the people they serve. Civitas works with leaders

from across the political spectrum to forge bold bipar-

tisan and cutting-edge campaigns that address criti-

cal societal challenges.

Clean Yield Asset Management is an SEC-

registered investment advisor serving social inves-

tors.

CloudFlare, Inc. offers advanced web security, dis-

tributed denial of service attack mitigation, and con-

tent delivery solutions. CloudFlare is a community of

over 2 million websites.

CMIT Solutions of Seattle Downtown offers in-

formation technology consulting and services to small

and medium sized businesses in the Seattle area.

The Coca-Cola Company, headquartered in Atlan-

ta, is one of the world’s largest beverage companies,

refreshing consumers with more than 500 sparkling

and still brands. Together with its bottling partners,

it ranks among the world’s top 10 private employers

with more than 700,000 system associates.

Cohen & Associates is a professional development

organization committed to leading the market in the

delivery of effective, results-based training programs

and learning materials to help our clients maximize

their full human resource potential.

Colgate-Palmolive Company is a global consumer

products company which manufactures and distrib-

utes oral, personal, and home care and pet nutrition

- App 17-

products to consumers in over 200 different countries

around the world.

Columbia FunMap, Inc. publishes maps and travel

guides targeting gay and lesbian travelers through-

out the U.S. and Canada.

Comcast Corporation is a global media and tech-

nology company with two primary businesses, Com-

cast Cable and NBCUniversal. Comcast Cable is the

nation's largest video, high-speed Internet and phone

provider to residential customers under the XFINITY

brand and also provides these services to businesses.

NBCUniversal operates news, entertainment and

sports cable networks, the NBC and Telemundo

broadcast networks, television production operations,

television station groups, Universal Pictures and

Universal Parks and Resorts.

The Computer Butler is an IT support and man-

aged services company serving the greater Nashville,

Tennessee area.

ConAgra Foods, Inc. is one of North America’s

largest packaged food companies with branded and

private branded food found in 99 percent of America’s

households, as well as a strong commercial foods

business serving restaurants and foodservice opera-

tions globally. Headquartered in Omaha, Nebraska,

ConAgra Foods employs more than 30,000 people na-

tionally and around the globe.

The Corcoran Group, a leading residential real es-

tate brokerage company in New York City, operates

40 offices with 2,200 sales associates serving Manhat-

- App 18 -

tan, Brooklyn, the Hamptons, the North Fork, Shel-

ter Island, Delray Beach and Palm Beach, Florida.

The Corcoran Group is part of NRT LLC, the nation’s

largest residential real estate brokerage company and

a subsidiary of Realogy Holdings Corp. that operates

Realogy’s company-owned real estate brokerage offic-

es.

Corner Brewery, LLC, also known as the Arbor

Brewing Company’s Microbrewery, is located in the

Historic Depot Town Neighborhood of Ypsilanti, MI.

Corning Incorporated, headquartered in Corning,

New York, and employing approximately 34,600 peo-

ple globally, is a world leader in the manufacture of

specialty glass and ceramics. Drawing on more than

160 years of materials science and process engineer-

ing knowledge, Corning creates and makes keystone

components that enable high-technology systems for

consumer electronics, mobile emissions control, opti-

cal communications and life sciences.

Cox Enterprises, Inc. is a leading communications,

media and automotive services company. Headquar-

tered in Atlanta, our more than 50,000 employees

serve customers across the country and around the

world through three divisions: Cox Communications,

the third largest cable operator in the country; Cox

Automotive, a portfolio of automotive-related services

including AutoTrader.com and Kelley Blue Book; and

Cox Media Group, which includes television and radio

stations, digital media and newspapers.

- App 19-

Crazy Misfits Pet Services is a pet service compa-

ny based in Kent, Washington providing services in 8

cities.

Credit Suisse Securities (USA) LLC is one of the

world’s leading financial services providers and part

of the Credit Suisse group of companies, offering cli-

ents its expertise in private banking, investment

banking and asset management. With offices nation-

wide, the largest U.S. office is located in New York.

Cummins Inc., a global power leader, and a corpora-

tion of complementary business units that design,

manufacture, distribute and service diesel and natu-

ral gas engines and related technologies, including

fuel systems, controls, air handling, filtration, emis-

gion solutions and electrical power generation sys-

tems. Headquartered in Columbus, Indiana, Cum-

mins currently employs approximately 54,600 people

worldwide and serves customers in approximately

190 countries and territories through a network of

approximately 600 company-owned and independent

distributor locations and approximately 7,200 dealer

locations.

Cupcake Royale, founded in 2003, is a cupcake

bakery and café located in Seattle, Washington.

CVS Health Corporation is a pharmacy innovation

company helping people on their path to better

health. Through its 7,800 retail pharmacies, more

than 900 walk-in medical clinics, a leading pharmacy

benefits manager with more than 65 million plan

members, and expanding specialty pharmacy ser-

vices, CVS enables people, businesses and communi-

App 20 -

ties to manage health in more affordable, effective

ways. Headquartered in Woonsocket, Rhode Island,

CVS employs approximately 205,000 people.

Dallas Voice is a leading media source for the LGBT

community in Texas. Published for 30 years in Dal-

las-Fort Worth, the Dallas Voice is distributed in five

counties, 23 cities and 62 zip codes.

Dana-Farber Cancer Institute, Inc. is a not-for-

profit hospital and research institute located in Bos-

ton, Massachusetts that provides care to children and

adults with cancer while advancing the understand-

ing, diagnosis, treatment, cure and prevention of can-

cer and related diseases. Dana-Farber employs more

than 4,000 people.

Danaher Corporation is a global science and tech-

nology innovator in health care, environmental, and

industrial businesses. Danaher has 71,000 associates

worldwide.

David J. Jarrett, P.C. is a personal injury and in-

surance defense law firm located in Michigan.

David Kosar Insurance Agency is a full-service

insurance agency offering property, auto, life, special-

ty personal lines, commercial and business insurance

products. We are located in Everett, Washington and

write insurance across the entire state of Washing-

ton.

David Mack Henderson Income Tax Prepara-

tion, located in Fort Worth, Texas, is an income tax

preparer with clients all over the United States.

- App 21 -

DCI Group AZ, L.L.C. is a leading public affairs

company with its principal place of business in Wash-

ington, DC. Its public affairs services include strate-

gic guidance for legislative, regulatory and communi-

cations challenges, media development/relations,

message development, community outreach, crises

management and strategic alliances. DCI Group

serves clients nationwide and internationally.

Deloitte LLP is a partnership with more than

65,000 partners, principals, and employees who pro-

vide audit, consulting, tax and advisory services to

many of the world’s most admired brands, including

80 percent of the Fortune 500. Our people work

across more than 20 industry sectors to deliver meas-

urable and lasting results.

Delta Air Lines, Inc. serves nearly 165 million cus-

tomers each year. With an industry-leading global

network, Delta and the Delta Connection carriers of-

fer service to 319 destinations in 59 countries on six

continents. Headquartered in Atlanta, Delta employs

nearly 80,000 employees worldwide and operates a

mainline fleet of more than 700 aircraft.

Depository Trust & Clearing Corporation

(DTCC), through its subsidiaries, provides clearing,

settlement and information services. In addition,

DTCC is a leading processor of mutual funds and in-

surance transactions. DTCC is headquartered in New

York.

The Desert Business Association has been com-

mitted to the promotion of LGBT businesses and al-

lied businesses since 1979. We are the Coachella Val-

App 22 -

ley’s only gay business association comprised of over

300 members. Our mission is to champion opportuni-

ty, development, and advocacy for our LGBT & allied

business community.

Deutsche Bank AG is a leading global investment

bank headquartered in Frankfurt, Germany, with

major hubs in London, New York, Sao Paulo, Dubai,

Hong Kong and Tokyo. With 10,000 of its 100,000

employees in the United States, Deutsche Bank offers

financial services throughout the world.

Diageo North America, Inc. is an indirect subsidi-

ary of Diageo plc, a public limited company in Eng-

land and Wales. Diageo is a global leader in beverage

alcohol with brands including Johnnie Walker,

Crown Royal, Buchanan’s and Bulleit whiskies,

Smirnoff, Ciroc and Ketel One vodkas, Captain Mor-

gan, Baileys, Don Julio, Tanqueray and Guinness.

Diageo North America has approximately 3,000 US

employees; 23 business offices across the US and

Canada; 12 bottling, distilling, blending and manu-

facturing sites in Illinois, Kentucky, Maryland, On-

tario, and Quebec; distilleries in Manitoba, Tennes-

see, and the U.S. Virgin Islands; and, 7 wineries and

wine production facilities in California.

DIRECTV supports the diversity of our more than

30,000 employees whose talents and unique life expe-

riences help us transform what TV means to the

world. As one of the world’s leading providers of digi-

tal television entertainment services, we deliver a

premium video experience to more than 39 million

customers in the U.S. and Latin America. In the U.S.,

DIRECTV offers its over 20 million customers access

- App 23 -

to more than 195 HD channels, exclusive sports pro-

gramming such as NFL SUNDAY TICKET™, Emmy-

award winning technology, and a track record of high

customer satisfaction.

DocuSign® is The Global Standard for Digital

Transaction Management®. DocuSign helps more

than 100,000 companies across nearly every industry

and department make their digital transformation.

More than 50 million people in 188 countries turn to

DocuSign to manage their most important transac-

tions—digitally. DocuSign’s DTM platform supports

legally compliant signature processes tailored to meet

requirements globally with localization in 43 lan-

guages.

Domini Social Investments LLC is a woman-

owned and managed SEC-registered investment ad-

viser that specializes exclusively in socially responsi-

ble investing.

The Dow Chemical Company, based in Midland,

Michigan, combines the power of science and technol-

ogy to passionately innovate what is essential to hu-

man progress. In 2014, Dow employed approximately

53,000 people worldwide. The Company’s more than

6,000 products are manufactured at 201 sites in 35

countries across the globe.

Dreamcatcher Arts and Publishing Ltd. is a pro-

gressive comic strip and magazine publisher based in

Lacey, Washington.

App 24 -

Dropbox, Inc., based in San Francisco, California, is

a service that lets you bring all your photos, docu-

ments, and videos anywhere, and share them easily.

DuPont is a world leader in market-driven innova-

tion and science. For more than 200 years, DuPont

has brought world-class science and engineering to

the global marketplace through innovative products,

materials and services. Our market-driven innova-

tion introduces thousands of new products and patent

applications every year, serving markets as diverse

as agriculture, nutrition, electronics and communica-

tions, safety and protection, home and construction,

transportation and apparel.

eBay Inc., headquartered in San Jose, California,

and employing more than 30,000 people, is a global

commerce platform and payments leader, connecting

millions of buyers and sellers through online plat-

forms including eBay, PayPal, and GSI.

Edelman is a leading global communications mar-

keting firm with more than 5,500 employees in 65 cit-

ies worldwide; we partner with many of the world’s

largest and emerging businesses and organizations,

helping them evolve, promote and protect their

brands and reputations.

Eldercare Consulting, based in Seattle, Washing-

ton, provides project management services for seniors

and their families.

Electronic Arts Inc. is a leading global interactive

entertainment software company that delivers

games, content and online services for Internet-

- App 25 -

connected consoles, personal computers, mobile

phones and tablets.

EnduringHydro, LLC is a clean energy company

headquartered in Chevy Chase, Maryland that devel-

ops hydroelectric power plants at existing dams,

seeking to increase the electricity production from

non-fossil fuel sources.

Ernst & Young LLP is a member firm of the global

EY organization, providing assurance, tax, transac-

tion and advisory services in offices throughout the

United States. Ernst & Young member firms have

more than 190,000 people worldwide.

The Estée Lauder Companies Inc. is one of the

world’s leading manufacturers and marketers of qual-

ity skin care, makeup, fragrance and hair care prod-

ucts. Founded in 1946 and headquartered in New

York City, the Company’s products are sold in over

150 countries and territories.

Event Rents is a provider of special event rental

items and services.

Everything Real Estate LLC is a professional real

estate services firm located in Fort Worth, Texas of-

fering client and customer representation, consulta-

tion and property management services.

Express Movers Inc. is local, family owned Seattle

moving company that has been in business since

1993.

- App 26 -

Facebook, Inc., based in Menlo Park, California, is

a social media service with more than one billion us-

ers.

Farella Braun + Martel, LLP represents clients

throughout the United States and abroad in sophisti-

cated business transactions and high-stakes commer-

cial, civil and crimina] litigation. Founded in 1962, we

are headquartered in San Francisco and maintain an

office in the Napa Valley.

Fastsigns is a sign and graphics company.

Fenwick & West LLP is a law firm with more than

600 partners and employees in California, Idaho,

Vermont and Washington, providing comprehensive

legal services to technology and life sciences compa-

nies.

First Data Corporation is a global provider of elec-

tronic commerce and payment solutions for mer-

chants, financial institutions, and card issuers with

operations in 34 countries, serving approximately 6.2

million merchant locations.

lst Security Bank is a community bank operating

primarily in the Puget Sound region of Washington

State.

lstdibs.Com, Inc. is a leading online marketplace

for rare and desirable objects, bringing together more

than 2,000 of the world’s dealers specializing in jew-

elry & watches, furniture, fine art, and collectibles.

- App 27 -

FIT Technologies is a female business enterprise

and LGBT-certified firm headquartered in Cleveland,

Ohio. FIT provides a full range of managed IT ser-

vices from network design and monitoring to Inter-

net, VoIP, field support, help desk, IT needs assess-

ments and CIO consultation to businesses and organ-

izations throughout Ohio and in cities across the

United States.

Flanery CPA is a CPA firm located in the greater

Seattle, Washington area.

Full Court Press Communications is a full service

public relations, public affairs, social media and crisis

communications agency located in Oakland, Califor-

nia.

G.A.W., Inc. is a manufacturer and distributor of

pneumatic tools and accessories.

The Gay & Lesbian Chamber of Commerce Ne-

vada (GLCCNV) advances the prosperity, equality

and inclusivity of Nevada’s gay, lesbian, bisexual,

transgender and allied business community through

referrals, education, networking, advocacy and sup-

plier diversity opportunities. GLCCNV was estab-

lished in 2013 as the local affiliate of the National

Gay & Lesbian Chamber of Commerce (NGLCC).

General Electric Company is one of the largest

and most diversified infrastructure and financial ser-

vices corporations in the world. With products and

services ranging from aircraft engines, power genera-

tion, oil and gas production equipment, and house-

hold appliances to medical imaging, business and

- App 28 -

consumer financing and industrial products, GE does

business in more than 150 countries and employs ap-

proximately 307,000 people worldwide.

General Mills, Inc. is one of the world’s leading food

companies, operating in more than 100 countries

around the world. Its brands include Cheerios, Fiber

One, Haagen-Dazs, Nature Valley, Yoplait, Betty

Crocker, Pillsbury, Green Giant, Old El Paso, Wan-

chai Ferry, Yoki and more. Headquartered in Minne-

apolis, Minnesota, Gener~! Mills has approximately

43,000 employees worldwide.

Gensler is a global architecture, design, planning

and consulting firm with more than 4,800 profession-

als in 46 offices around the world.

Gilt Groupe Holdings, Inc., based in New York

City and employing more than 1,100 people, is an

online shopping destination, offering members special

access to leading fashion, home décor and unique lo-

cal activities in select cities.

GlaxoSmithKline LLC is the United States-based

affiliate of GlaxoSmithKline plc, a science led global

pharmaceutical, vaccines, and consumer healthcare

company. The Company manufactures medicines for

major disease areas, including respiratory, HIV, dia-

betes, vaccines for infectious diseases and consumer

products for wellness, oral health and nutrition.

Gleason & Associates Claims Services, in Fern-

dale, Michigan, provides insurance adjusting, inves-

tigative and surveillance services to insurers

throughout Michigan.

- App 29 -

Go Factory, Inc. is a software company located in

San Francisco, California that helps enterprises and

businesses to create mobile collaboration solutions

that integrate data and content with people and sys-

tems.

Goethel Engelhardt, PLLC is a law firm and pro-

fessional service limited liability company located in

Michigan.

The Goldman Sachs Group, Inc. is a leading glob-

al investment banking, securities and investment

management firm that provides a wide range of fi-

nancial services to a substantial and diversified client

base that includes corporations, financial institu-

tions, governments and high-net-worth individuals.

The firm is headquartered in New York City.

Google, Inc. is a global technology leader focused on

improving the ways people connect with information,

with headquarters in California.

Goulston & Storrs, P.C. is an international law

firm practicing real estate, environmental, retail, tax

and other practices in Boston, New York, and Wash-

ington, D.C.

Great Officiants LLC performs wedding ceremo-

nies, has a wedding chapel and issues marriage li-

censes in the Southern California area.

The Greater Connecticut Gay and Lesbian

Chamber of Commerce’s purpose is to create, iden-

tify and enhance business opportunities for LGBT

- App 30 -

and LGBT-allied organizations, thereby fostering a

more inclusive and vibrant Connecticut economy.

Greater San Diego Business Association was

founded in 1979 and is the LGBT chamber of com-

merce in San Diego County, California, with over 800

members.

Greater Seattle Business Association is the

LGBT chamber of commerce in Seattle, Washington.

Greensulate provides sustainable building consult-

ing in New York City, Long Island, the San Francisco

Bay Area, and Los Angeles.

Grossman Marketing Group, a fourth-generation

family business, is a full-service provider of market-

ing solutions to customers in fields as varied as fi-

nancial services, law, biotechnology, education, and

the arts.

Group Health Cooperative is a non-profit health

care system linking care delivery and insurance cov-

erage in order to achieve one goal — affordable, quali-

ty health care for all. Group Health helps nearly

600,000 patients throughout Washington state.

Groupon, headquartered in Chicago, is a global

leader of local commerce, offering consumers a vast

marketplace of deals all over the world and small

businesses a suite of products and services to help

them attract, retain and interact with customers.

Growing Hope is an Ypsilanti, Michigan based non-

profit. Its mission involves helping people improve

- App 31 -

their lives and communities through gardening and

healthy food access.

Harrell Remodeling is a full-service residential de-

sign and remodeling company based in Mountain

View, California and operating in the Silicon Valley

with 40 employees.

The Hartford Financial Services Group, Inc.,

headquartered in Hartford, Connecticut and with

more than 200 years of expertise, is a leader in prop-

erty and casualty insurance, group benefits and mu-

tual funds, widely recognized for its service excel-

lence, sustainability practices, trust and integrity.

Healthline provides health information and technol-

ogy solutions that help healthcare organizations and

everyday people make more informed healthcare de-

cisions, improve outcomes and reduce costs.

Hewlett-Packard Company is an innovative global

information technology company providing solutions

for printing, personal computing, IT infrastructure,

Cloud, and enterprise software and services.

Hilton Worldwide Holdings, Inc. is one of the

largest and fastest growing hospitality companies in

the world, with more than 4,200 hotels, resorts and

timeshare properties comprising more than 690,000

rooms in 93 countries and territories. More than

300,000 team members proudly serve in our proper-

ties and corporate offices around the world.

Holdredge Wines is a small, family-owned pinot

noir producer in Healdsburg, California.

- App 32 -

Homeward Pet Adoption Center isone of the

leading non-profit, no-kill animal shelters in Wash-

ington State.

Horizon Air Industries, Inc. is an airline serving

cities throughout Arizona, California, Oregon, Wash-

ington, Idaho, Montana, and Nevada; Baja California

Sur (Mexico); and British Columbia and Alberta

(Canada).

House Packard LLC is a small law firm headquar-

tered in Kansas City, Missouri, that advocates for

those who are marginalized because of their financial

status, their identification as LGBT or because they

have been injured.

HSBC provides retail banking and wealth manage-

ment, commercial banking, private banking, asset

management and global banking and markets exper-

tise to millions of customers, ranging from individual

clients to corporate and institutional clients.

Ikard Wynne LLP is an Austin, Texas-based law

firm offering services in family law, property tax liti-

gation, commercial litigation, technology litigation,

business and transactions practice, appellate prac-

tice, and public policy.

The Independence Business Alliance provides

opportunities, access and resources to LGBT profes-

sionals and allies in the Greater Philadelphia area.

The Inland Northwest Business Alliance is Spo-

kane's Gay Chamber of Commerce with members in

Eastern Washington and North Idaho.

- App 33 -

Insala, Ltd., based in Arlington, Texas, is a multi-

national talent development technology and consult-

ing firm supporting career development, transition,

mentoring and corporate alumni activities in 20 lan-

guages for over 2 million employees in 180 countries.

Inspirato, LLC, headquartered in Denver, Colorado,

and employing nearly 300 people, provides luxury va-

cation solutions for discerning travelers.

Integrated Archive Systems, Inc. is a corporation

based in Palo Alto, California, that provides data

management solution and services.

Integrity Law Group is a law firm based in Seattle,

Washington that focuses on immigration, family law,

bankruptcy, estate planning, escrow, personal injury,

short sales, and loan modifications.

Intel Corporation is the world’s largest semicon-

ductor manufacturer and is also a leading manufac-

turer of computer, networking, and communications

hardware and software products. Intel is headquar-

tered in Santa Clara, California.

Intuit Inc. is a leading provider of innovative busi-

ness and financial management solutions for small

businesses, consumers, accounting professionals and

financial institutions. With 8,000 employees in offices

around the world, the company has been recognized

for its commitment to diversity for ten consecutive

years by the Human Rights Campaign.

INUS Group, LLC is a business consulting company

working with small businesses.

App 34 -

Jackson Hole Group LLC is a consulting firm

headquartered in San Francisco, California that ad-

vises client Boards, CEO’s and C-Suite executives on

key business, organizational and executive issues.

Jagod Designs is an interior design business located

in Seattle, Washington.

Jazz Pharmaceuticals, Inc. is a specialty biophar-

maceutical company that identifies, develops and

commercializes innovative products. It has offices in

California and Pennsylvania.

Jenn T. Grace International LLC, headquartered

in Hartford County, Connecticut, focuses on educat-

ing businesses on how to do business with and mar-

ket to the lesbian, gay, bisexual, and transgender

community.

Jennifer Brown Consulting is a global diversity

and inclusion firm with a passion for building more

inclusive workplaces and a deep expertise in all re-

lated aspects of human capital and talent manage-

ment.

JetBlue Airways Corporation is a U.S. passenger

airline headquartered in New York and operating

throughout the United States and internationally

throughout the Caribbean and Latin America. Jet-

Blue employs over 16,000 crewmembers, predomi-

nantly within the United States.

The Jim Henson Company, based in Hollywood,

California, is an established leader in family enter-

- App 35 -

tainment and is recognized worldwide as an innova-

tor in puppetry, animatronics and digital animation.

Johnson & Johnson embraces research and science

- bringing innovative ideas, products and services to

advance the health and well-being of people. Our

nearly 129,000 employees at more than 275 Johnson

& Johnson operating companies in 150 countries (in-

cluding all 50 states) work with partners in health

care to touch the lives of over a billion people every

day, throughout the world.

Johnston, Kinney and Zulaica LLP, headquar-

tered in San Francisco, California, focuses on custom-

ized estate planning from foundational to complex,

including international and cross border planning,

charitable planning and wealth transfer, trust and

probate services, tax advice, and helps families with

formation and dissolution issues.

Jonathan L. Bowman, Attorney at Law, PS, is a

law firm in Seattle, Washington, focusing on estate

planning and probate, corporate and business law,

real estate law, and domestic partnership and same-

sex marriage legal matters.

JPMorgan Chase & Co. is a top global financial

services firm and a leader in investment banking, fi-

nancial services for consumers and small businesses,

commercial banking, and asset management. A com-

ponent of the Dow Jones Industrial Average, JPMor-

gan Chase serves millions of consumers in the United

States and many of the world’s most prominent cor-

porate, institutional and government clients.

- App 36 -

Julian Chang Consulting, Inc., based in San

Francisco, California, provides strategic advice to

Fortune 500 companies in the areas of community re-

lations, government affairs, and philanthropic part-

nerships.

kapchur.us photography is a photography compa-

ny that photographs weddings, events, people and

products.

The Kathy A. Janssen Foundation is a nonprofit

foundation located in Commerce, Michigan that pro-

vides support for cancer research, funds secondary

education scholarships, and assists with treatment

costs for uninsured and under-insured cancer pa-

tients.

Kazan, McClain, Satterley, & Greenwood, PLC

is a law firm with offices in Oakland, California and a

national practice focused on the representation of as-

bestos cancer victims from all over the United States.

Keir Jones Agency — State Farm, located in Long

Beach, California, provides insurance and financial

services guidance.

Keker & Van Nest LLP is a San Francisco, Califor-

nia law firm that tries and litigates high-stakes civil

and criminal] cases throughout the country.

KEO Marketing Inc., a Phoenix, Arizona based B2B

marketing firm, delivers innovative marketing solu-

tions that achieve tangible and substantial results.

- App 37 -

Kimberly-Clark Corp., headquartered in Irving,

Texas, and employing more than 42,000 employees

worldwide, is a global consumer product company

providing essentials for a better life through its well-

known brands including KLEENEX, HUGGIES, KO-

TEX, COTTONELLE and the SCOTT family of prod-

ucts.

Kimpton Hotel & Restaurant Group, LLC oper-

ates hotels and restaurants in 27 cities throughout

the United States. Kimpton and its subsidiaries em-

ploy approximately 8,200 employees.

Kollmar Sheet Metal Works, Inc. is a metal fabri-

cation and installation contractor doing residential

and commercial work, located in Seattle, Washington.

Kotzan Chiropractic, located in San Carlos, Cali-

fornia, is a provider of chiropractic care.

KPMG LLP is a professional services firm that pro-

vides audit, tax and advisory services to a wide range

of commercial, non-profit and government entities.

KPMG LLP is the United States member firm of

KPMG International Cooperative and has over 100

offices and over 27,000 employees, partners, and

principals in the United States.

Lambda Business Association is the LGBT Cham-

ber of Commerce for Southern Nevada since 1991.

Our membership includes over 270 businesses, com-

munity organizations and elected officials that are

LGBT-owned and LGBT allied. We believe equality,

non-discrimination and social justice are good for

business.

- App 38 -

Laparoscopic Institute for Gynecologic Oncolo-

gy, based in Portola Valley, California, produces

comprehensive courses on minimally invasive gyneco-

logic surgery.

Larson Marketing & Communications LLC is a

marketing and communications consulting firm serv-

ing the healthcare, professional services, and non-

profit sectors in the greater Seattle, Washington ar-

ea.

Laughton Properties is a full-service property

management company located in Sacramento, Cali-

fornia.

Law Offices of Joel L. Sogol is a criminal defense

law firm located in Tuscaloosa, Alabama.

Law Office of Lisa E. Schuchman is a law firm in

Seattle, Washington.

Law Office of Lorie L. Burch, PC is an estate

planning & probate law firm located in Dallas, Texas.

Law Offices of Robin L. Bodiford, P.A., based in

Fort Lauderdale, Florida, provides legal services in

the areas of estate planning and administration,

bankruptcy, domestic settlements and domestic

agreements.

The Law Office of Susan K. Fuller, PLLC, based

in the Pacific Northwest provides general counsel

services for small businesses, provides arbitration

services, and represents clients in federal and state

courts on a wide variety of issues.

- App 39 -

Levi Strauss & Co. is one of the world’s largest

brand-name apparel marketers, with products sold

under the Levi's®, Dockers®, Signature by Levi

Strauss & Co.™ and Denizen™ brands. Based in San

Francisco, California, it has roughly 16,000 employ-

ees worldwide.

Liberty Burger is a family owned business with six

locations.

Lieff Cabraser Heimann & Bernstein, LLP is a

law firm specializing in complex individual and class

actions on behalf of consumers, investors, employees,

patients, and small business owners, with 60 attor-

neys across offices in San Francisco, California; New

York, New York; and Nashville, Tennessee.

Life & Love Celebrations provides ceremonial ser-

vices in Los Angeles, Long Beach, Orange County and

surrounding areas.

Link in the Chain Foundation, Inc. (LINK) is a

South Florida-based, charitable non-profit organiza-

tion, dedicated to promoting and facilitating volun-

teerism and philanthropy within local communities

across the Americas. LINK’s mission is to connect the

needed with those in need.

Littler Mendelson, P.C. is a labor and employment

law firm with more than 900 lawyers in 55 offices

across the U.S. and globally.

LNT, Inc., which incorporated in 1982, is a wholesale

gem and findings business supplying retailers

- App 40 -

throughout the United States with a variety of prod-

ucts related to the jewelry industry.

The Long Beach Gay and Lesbian Chamber of

Commerce’s mission and vision is to have a positive

impact on the LGBT business and professional com-

munity and its allies.

Lori Karbal et al is a hair and beauty supply store.

Loring, Wolcott & Coolidge Trust, LLC is a mul-

tifamily office dedicated to providing highly personal-

ized fiduciary and investment services to high net

worth individuals and families.

The Los Angeles Gay & Lesbian Chamber of

Commerce increases the economic strength of LGBT

and allied professionals through business develop-

ment, visibility advocacy and leadership.

Main Street Hair Shoppe, Ltd. has been, for 26

years, a family owned hair salon in the small rural

community of Whitmore Lake, Michigan.

Marriott International, Inc. is a leading lodging

company based in Bethesda, Maryland with more

than 4,100 properties in 79 countries and territories.

The company operates and franchises hotels and re-

sorts under 18 brands, including The Ritz-Carlton,

Renaissance and Courtyard, and directly employs ap-

proximately 200,000 associates worldwide.

Marsh & McLennan Companies, Inc. is a global

professional services firm offering clients advice and

solutions in the areas of risk, strategy, and human

- App 41 -

capital. It includes Marsh (insurance broking and

risk management), Guy Carpenter (risk and reinsur-

ance intermediary services), Mercer (talent, health,

retirement, and investment consulting) and Oliver

Wyman (management consulting).

Massachusetts Mutual Life Insurance Company

is a life insurance company with its principal place of

business in Massachusetts.

McGraw Hill Financial, Inc. is a leading financial

intelligence company providing the global capital and

commodity markets with independent benchmarks,

credit ratings, portfolio and enterprise risk solutions,

and analytics. The Company’s brands include Stand-

ard & Poor’s Ratings Services, S&P Capital IQ, S&P

Dow Jones Indices, Platts, CRISIL, and J.D. Power.

McKesson Corporation is a healthcare services

and information technology company dedicated to

making the business of healthcare run better. We

partner with payers, hospitals, physician offices,

pharmacies, pharmaceutical companies and others

across the spectrum of care to build healthier organi-

zations that deliver better care to patients in every

setting. McKesson helps its customers improve their

financial, operational, and clinical performance with

solutions that include pharmaceutical and medical-

surgical supply management, healthcare information

technology, and business and clinical services.

McKinsey & Company, Inc. is a giobal manage-

ment consulting firm that serves leading businesses,

governments, non-governmental organizations, and

not-for-profits. We help our clients make lasting im-

- App 42 -

provements to their performance and realize their

most important goals.

Merca Property Management is a proud supporter

of diversity and equal rights.

The Miami-Dade Gay & Lesbian Chamber of

Commerce’s mission is to promote a unified and

thriving, gay and gay-friendly, business and profes-

sional community throughout Miami-Dade County.

Microsoft Corporation is a worldwide leader in

software, services, devices and solutions that help

people and businesses realize their full potential. To

create technology that empowers the world, we need

a workforce that reflects the diversity of the world.

Diversity is central to both our values and our busi-

ness success.

The Mid-America Gay & Lesbian Chamber of

Commerce is an organization that advocates, pro-

motes and facilitates the success of the LGBT busi-

ness community and their allies through the guiding

principles of equality, inclusion, economics and edu-

cation. Our purpose is to create, identify and enhance

business opportunities for LGBT and LGBT-friendly

organizations, thereby fostering a more inclusive and

vibrant economy in Mid-America.

Miller & Olson LLP is a law firm with offices in

Sacramento and Burlingame, California.

Miller Shelton Group, LLC is an experiential mar-

keting company specializing in event production ser-

vices.

App 43 -

MillerCoors LLC is a joint venture of SABMiller plc

and Molson Coors Brewing Company. MillerCoors

seeks to become America’s best beer company

through an uncompromising promise of quality, a

keen focus on innovation and a deep commitment to

sustainability.

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo,

P.C., established in 1933, is a full-service, 500-

attorney law firm with eight offices in the United

States and the United Kingdom.

Mona Smith PLLC is a law firm in Seattle, Wash-

ington focusing on the transactional and litigation

needs of clients in the areas of business law, real es-

tate, estate planning and LGBT families.

Moody’s Corporation is an essential component of

the global capital markets, providing credit ratings,

research, tools and analysis that contribute to trans-

parent and integrated financial markets. Moody’s

Corporation is the parent company of Moody’s Inves-

tors Service, which provides credit ratings and re-

search covering debt instruments and securities, and

Moody’s Analytics, which offers leading-edge soft-

ware, advisory services and research for credit and

economic analysis and financial risk management.

The Corporation employs approximately 9,900 people

worldwide and maintains a presence in 33 countries.

Morgan Miller Plumbing provides residential and

commercial plumbing services for the entire Kansas

City metropolitan area and beyond.

App 44 -

Morgan Stanley is a leading global financial ser-

vices firm providing investment banking, securities,

investment management and wealth management

services. With offices in more than 43 countries, the

Firm’s employees serve clients worldwide including

corporations, governments, institutions and individu-

als.

MWW Public Relations, headquartered in East

Rutherford, New Jersey with about 230 employees

globally, is a public relations and marketing firm spe-

cializing in consumer lifestyle marketing, digital and

social media marketing, corporate communications,

public affairs and government relations, technology

and visual branding.

NAMI Dallas, Inc., located in Dallas, Texas, is a

non-profit organization that provides support, educa-

tion and advocacy for people with mental illness and

their friends and family.

The Nashville LGBT Chamber of Commerce ad-

vances common business interests, economic growth,

and equality in the workplace for our membership

made up of over 210 LGBT members, businesses, and

allies.

The National Gay & Lesbian Chamber of Com-

merce is the business voice of the LGBT community

and is the largest global not-for-profit advocacy or-

ganization specifically dedicated to expanding eco-

nomic opportunities and advancements for LGBT

people.

- App 45 -

Nationwide Mutual Insurance Company, a di-

versified insurance and financial services organiza-

tion based in Columbus, Ohio, employs 33,000 associ-

ates and provides a full range of insurance and finan-

cial services.

Neumann Capital Management, LLC is a wealth

management firm based in Foster City, California

providing comprehensive investment management

and financial planning services.

The New England Patriots are four-time National

Football League Super Bowl Champions. The Kraft

Group, headquartered in Foxborough, Massachusetts,

is a diversified holding company with assets in forest

product distribution, paper and packaging manufac-

turing, sports and entertainment, real estate devel-

opment, private equity and venture investing. In ad-

dition to the New England Patriots, the Kraft Group’s

sports holdings include Major League Soccer’s five-

time conference champion New England Revolution

and the venue both teams call home, Gillette Stadi-

um.

New Leaf Columbus is dedicated to strengthening

LGBTQ communities of color through dialogue that

advances visibility, acceptance and involvement.

New York Life Insurance Company, founded in

1845, is one of the largest mutual life insurance com-

panies in the United States and in the world. Head-

quartered in New York City, New York Life’s family

of companies offers life insurance, retirement income,

investments and long-term care insurance. -

- App 46 -

Nifty Hoops, LLC designs, manufactures and in-

stalls hoophouses to help four-season farmers grow

the fresh and healthy food we all want to eat.

NIKE, Inc., based near Beaverton, Oregon, is a

world-leading designer, marketer and distributor of

authentic athletic footwear, apparel, equipment and

accessories for a wide variety of sports and fitness ac-

tivities.

Nixon Peabody LLP is a law firm of over 700 attor-

neys across the U.S., Europe and Asia. Nixon Pea-

body is headquartered in Boston, Massachusetts.

Northrop Grumman Corporation is a leading

global security company providing innovative sys-

tems, products and solutions in unmanned systems,

cyber, C4ISR (Command, Control, Communications,

Computers, Intelligence, Surveillance and Reconnais-

sance), and logistics and modernization to govern-

ment and commercial customers worldwide.

North Texas GLBT Chamber of Commerce,

headquartered in Dallas, Texas, and serving the en-

tire Dallas-Fort Worth area, works to achieve equali-

ty through economic development and advocacy.

OBOX Solutions, located in Dallas, Texas, is a full

service staffing team that encompasses a complete

range of placement options.

Office Depot, Inc. is a leading global provider of

products, services, and solutions for every workplace.

The company employs approximately 56,000 associ-

ates, and serves consumers and _. businesses

- App 47 -

in 56 countries with more than 1,800 retail stores, e-

commerce sites and a dedicated business-to-business

sales organization.

The Ogilvy Group, Inc. is a corporation engaged in

advertising and marketing communications and

based in New York.

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

is one of America’s leading labor and employment

firms. In our 47 offices, located in 25 states, the U.S.

Virgin Islands, Mexico and Europe, we have more

than 700 attorneys and more than 1500 employees.

We represent employers of all sizes across many in-

dustries, including more than half of the Fortune 500.

We believe that diversity and inclusion are integral to

our outstanding performance and exceptional client

service.

ONE Community Media, LLC is an Arizona-based

business dedicated to educating, empowering, and

connecting a coalition of socially responsible busi-

nesses and individuals that support diversity, inclu-

sion and equality for all Arizonans.

1 Source Consulting Solutions, based in San Jose,

California, provides executive coaching and leader-

ship development programs and services to corpora-

tions and non-profits.

Oracle America, Inc. is a leading global technology

company, delivering hardware, middleware, applica-

tion software, database software, and operating sys-

tems that work together in the cloud and in the data

- App 48 -

center. Based in Redwood City, California, Oracle has

over 115,000 employees worldwide.

Orbitz Worldwide, Inc. headquartered in Chicago,

Illinois, is a leading global online travel company,

with nearly 1500 employees and $12 billion in annual

bookings.

Out & Equal Workplace Advocates is a premiere

nonprofit organization dedicated to achieving lesbian,

gay, bisexual and transgender workplace equality.

We collaborate with leading local, national, and glob-

al corporations, their executives, human resource pro-

fessionals, employee resource groups, and individuals

to provide leadership & professional development,

education, and research to create a culturally accept-

ing work environment free of discrimination.

Outerwall, Inc. is a leading provider of automated

retail kiosks (Redbox® entertainment, Coinstar®

money services, and ecoATM® electronics recycling)

in grocery stores, drug stores, mass merchants, malls,

and other retail locations in the United States, Cana-

da, Puerto Rico, the United Kingdom, and Ireland.

The company, which has approximately 2,800 em-

ployees, is headquartered in Bellevue, Washington.

Pakmode Publications, LLC dba Pakmode Media

+ Marketing is an Ypsilanti, Michigan based sports

and entertainment marketing company helping

teams, artists and colleges drive revenue through

traditional! and digital marketing platforms.

- App 49 -

Pandora Media, Inc. provides an internet radio

service that gives people music and comedy they love

anytime, anywhere, through connected devices.

PATH is an international nonprofit organization,

headquartered in the United States, that takes an

entrepreneurial approach to developing and deliver-

ing high-impact, low-cost solutions in more than 70

countries, from lifesaving vaccines and devices to col-

laborative programs with communities.

Peabody & Arnold LLP is a law firm in Boston. Its

practice focuses employment, professional liability,

and insurance law.

Pepper Hamilton LLP is a multi-practice law firm

with offices in Pennsylvania, Michigan, New York,

New Jersey, Delaware, the District of Columbia, Cali-

fornia and Massachusetts, and more than 500 law-

yers nationally. Founded in 1890, the firm provides

corporate, litigation and regulatory legal services to

leading businesses, governmental entities, nonprofit

organizations and individuals throughout the nation

and the world.

PepsiCo makes products that are enjoyed by con-

sumers in more than 200 countries and territories

around the world. PepsiCo’s product portfolio in-

cludes a wide range of enjoyable foods and beverages,

including Frito-Lay, Gatorade, Pepsi-Cola, Quaker

and Tropicana.

Pfizer Inc. is headquartered in New York and has

30,000 colleagues across the United States. Pfizer is

engaged in the discovery, development, manufacture

- App 50 -

and sale of many of the world’s best-known prescrip-

tion medicines and consumer healthcare products.

We are committed to applying science and our global

resources to improve health and well-being at every

stage of life. We are also committed to maintaining a

diverse and inclusive workplace for all colleagues, in-

cluding LGBT colleagues.

Pixelligent Technologies, LLC, producer of

PixClear™, is an advanced materials company that

delivers next generation materials for demanding ap-

plications in solid-state lighting, flat panel displays,

and optical components & films.

Plexus Education Foundation is a 501c3 organi-

zation whose mission is to improve the workplace en-

vironment for LGBT individuals through education,

research and professional development.

Plexus LGBT and Allied Chamber of Commerce

connects LGBT professionals and business owners,

and allied individuals and organizations to expand

the economic interest of stakeholder businesses, to

provide education programs and resources, and to

advocate for workplace equality.

Portland Area Business Association, Portland-

Area's LGBT Chamber of Commerce is in its twenty-

third year and is an affiliate of the NGLCC.

PricewaterhouseCoopers LLP is a member of the

PwC network of firms in 157 countries with more

than 195,000 people who are committed to delivering

quality in assurance, tax and advisory services.

- App 51-

PrideFest produces the Seattle Pride Festival and

also helps local upstart prides and provides material

support and advocacy for areas of the world where

Pride meets resistance or has not made a strong foot-

hold yet.

The PrintingWorks has provided top quality tradi-

tional offset printing and modern digital printing ser-

vices to customers in Sunnyvale, San Jose, and the

greater Silicon Valley since 1976.

Pro-Tec Data, Inc. is a national intellectual asset

protection consulting firm that provides a compre-

hensive array of trade secret and information protec-

tion strategy, identification, classification, policy, and

training services to high-tech, biotech, pharmaceuti-

cal, financial and manufacturing industries.

Procter & Gamble serves nearly five billion people

around the world with its brands, including Always®,

Ambi Pur®, Ariel®, Bounty®, Charmin®, Crest®,

Dawn®, Downy®, Duracell®, Fairy®, Febreze®,

Gain®, Gillette®, Head & Shoulders®, Lenor®,

Olay®, Oral-B®, Pampers®, Pantene®, SK-II®,

Tide®, Vicks®, Wella® and Whisper®. The P&G

community includes operations in approximately 70

countries worldwide.

ProTrials Research, Imc., headquartered in

Sunnyvale, California, and employing more than 170

staff across North America and the EU, is a clinical

research leader, supporting pharmaceutical, biotech-

nology, and medical device companies execute high

quality clinical studies worldwide.

- App 52 -

Prudential Financial, Inc., a financial services

leader, has operations in the United States, Asia, Eu-

rope, and Latin America. Prudential’s diverse and

talented employees are committed to helping individ-

ual and institutional customers grow and protect

their wealth through a variety of products and ser-

vices, including life insurance, annuities, retirement-

related services, mutual funds and investment man-

agement.

Puma Springs Vineyards is an organic and biody-

namic farming company in Healdsburg, California,

that grows and sells luxury wine grapes to Sonoma

County wineries.

Qualcomm Incorporated is a world leader in mo-

bile connectivity and computing technologies. With

more than 30,000 employees worldwide, Qualcomm

and its affiliated companies develop and sell chipsets

for mobile devices and broadly license their innova-

tions to the industry.

Quorum is a conduit for economic development. Our

work includes assisting and developing certified

GLBT owned enterprises and supporting their en-

trance into the supply chains through fully inclusive

Supplier Diversity programs as well as creating visi-

bility and business activity for all of our member

businesses and organizations.

RAFI Architecture and Design is a multifaceted

planning, architecture, and urban design firm with

three studios, with its primary office in Las Vegas,

Nevada.

- App 53 -

Rainbow Chamber of Commerce Silicon Valley

is located in Silicon Valley since 1999. Our member

businesses and business professionals are both of

LGBT- and allied-owned.

Ralph’s Regal Weddings performs wedding cere-

monies for all couples in the Spokane, Washington

and Coeur d’Alene, Idaho areas.

Ray Holley Communications provides writing and

editing services in Healdsburg, California.

RBC Capital Markets, LLC is a premier invest-

.ment bank that provides a focused set of products

and services to corporations, institutional investors

and governments around the world.

Replacements, Ltd., based in Greensboro, North

Carolina, operates replacements.com and is the larg-

est retailer of discontinued and active china, crystal,

flatware, and collectibles.

Restaurant Management Concepts is a restau-

rant consulting group located in Miami, Florida.

Reverberate! Marketing Communications, Inc.

is a marketing/public relations firm, based in Miami,

Florida.

Rising Tide Brewing Company is a brewery based

in Portland, Maine.

RJR Photography, based in Grand Rapids, Michi-

gan, is a full service photography provider.

- App 54 -

Robert H. Stutz Jr. CPA is a public accounting firm

located in Dallas, Texas.

Rockwell Automation, Inc. is a leading company

dedicated to industrial automation and information.

Headquartered in Milwaukee, Wisconsin, Rockwell

Automation employs about 22,500 people serving cus-

tomers in more than 80 countries.

Rotella & Hernandez, LLC, a law firm, is a 100%

owned lesbian business. Based in Florida, our office

handles immigration matters (nationwide), criminal

and civil matters.

The Sacramento Rainbow Chamber of Com-

merce serves gay, lesbian, bisexual and transgender

business owners, professionals and allies in the six-

county Greater Sacramento region.

Sadek Bonahoom PLC is a law firm that serves

small businesses and nonprofits in Detroit and its

surrounding areas.

The San Francisco Chamber of Commerce, rep-

resenting over 1,500 local businesses, attracts, sup-

ports and grows business through advocacy, economic

development and business development in San Fran-

cisco, California.

The San Francisco Giants are reigning World Se-

ries Champions and one of the oldest franchises in

Major League Baseball.

The Seattle Lesbian, LLC publishes a daily online

news magazine operating from offices in the Pacific

- App 55 -

Northwest and reaching communities around the

world.

Seattle Metropolitan Chamber of Commerce

represents 2,200 small, medium and large businesses

in the four-county Puget Sound region.

Sempra Energy has over 17,000 employees world-

wide. The Sempra Energy companies develop energy

infrastructure, operate utilities, and provide related

products and services to more than 32 million con-

sumers worldwide.

Seyfarth Shaw LLP is an international law firm

with more than 800 attorneys in the United States,

London, Shanghai, Melbourne and Sydney that offers

a national platform and an international gateway to

serve our client’s business and legal needs in litiga-

tion, employment, corporate, real estate and employ-

ee benefits.

Shingles Roofing LLC is a family owned roofing

and general contracting company.

Sidetrack, Inc., operates the Sidetrack Bar & Grill

is a popular restaurant located in the historic Depot

Town neighborhood of Ypsilanti, Michigan.

Simon, Schindler & Sandberg LLP is a full ser-

vice law firm providing trial and appellate services to

individuals and small businesses.

Skellenger Bender, P.S. is a Seattle, Washington

based law firm that serves individuals, families,

businesses, and governmental entities.

- App 56 -

Skyworks Solutions, Inc., based in Woburn, Mas-

sachusetts, is an innovator of high performance ana-

log semiconductors.

Sleeves Up Productions, LLC is a full service pro-

duction company dedicated to transforming ideas into

meaningful, moving, and colorful content.

Sow is a California inspired organic juice company

specializing in artisanal made to order juice and oth-

er beverages.

Spectra Law PS is a law firm with offices in Seattle

and Spokane, Washington that provides estate plan-

ning, probate, and small business services to the

LGBT community.

Spry Vision, Inc., located in Seattle, Washington,

provides sales, marketing and business solutions to

drive growth, increase revenue and unlock business

value.

St. Jude Medical, Inc. is a global medical device

manufacturer dedicated to transforming the treat-

ment of some of the world’s most expensive epidemic

diseases. Headquartered in St. Paul, Minnesota, St.

Jude Medical has four major clinical focus areas that

include cardiac rhythm management, atrial fibrilla-

tion, cardiovascular and neuromodulation.

Staples, Inc., headquartered outside of Boston, Mas-

sachusetts and with over 85,000 employees in over 20

countries, lets customers shop however and whenever

they want, whether it is in-store, online, on mobile

devices, or through the company’s online, pick-up in

App 57 -

store option. Staples offers products such as technol-

ogy, facilities and breakroom supplies, furniture,

safety supplies, medical supplies, and copy and print

services.

Starbucks Corporation. Since 1971, Starbucks Cof-

fee Company has been committed to ethically sourc-

ing and roasting the high-quality arabica coffee. To-

day, with stores around the globe, the company is a

premier roaster and retailer of specialty coffee in the

world. Through our unwavering commitment to excel-

lence and our guiding principles, we bring the unique

Starbucks Experience to life for every customer

through every cup.

Starrtek LLC, headquartered in Kearney, Missouri,

develops custom technology solutions across several

technology platforms.

State Street Corporation is a giobal leader in

providing financial services to institutional investors,

delivering solutions across investment management,

research and trading, and investment servicing.

Headquartered in Boston, Massachusetts, State

Street operates in 29 countries and serves clients in

more than 100 markets.

Steven Graves Insurance Agency is a full service

agency serving individuals, families and businesses

in Texas.

Stonewall Behavioral Health is a leading counsel-

ing and training business in North Texas specializing

in lesbian, gay, bisexual and transgender folks and

the people who love them. We are a group of licensed

- App 58 -

professional counselors who self-identify with the

very population of LGBT people we treat and train.

Stonewall Columbus, founded in 1981, operates the

only LGBT Community Center in central Ohio.

Stuffed Cakes, LLC, located in West Seattle, Wash-

ington, creates and sells custom cakes.

Sun Life Financial (U.S.) Services Company,

Inc. has approximately 2,300 employees in 43 states

who support the United States insurance operations

of Sun Life Financial Inc., a leading international fi-

nancial services company.

SunDaily is a research-based nutritional supple-

ment manufacturer committed to producing the high-

est quality products using only the most effective, bi-

oavailable ingredients.

Support.com, Inc., headquartered in Redwood Cit

This text is long and has been trimmed here. Open the source document for the complete record.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.

Amicus Curiae Brief — Obergefell v. Hodges · 576 U.S. 644 | Frix