IBM's alleged efforts tomake its workforce younger have already come under fire. The EqualEmployment Opportunity Commission has consolidated complaintsagainst IBM into a single, targeted investigation. (Photo:Bloomberg)

(Bloomberg) –International Business Machines Corp. managersdiscussed ways to make the company's workforce younger and move jobs overseas, according to apresentation filed in court recently.

The documents are at the center of a lawsuit againstIBM by a former executive who says he was fired based on hisage. A person familiar with the filings saidIBM couldn't verify whether the documents were real.

The presentation filed in December outlines a proposal to“correct seniority mix.” It also purports to detail how IBM could“lift and shift” jobs from its main markets in developed countriesto places such as Costa Rica and India.

The former employee asked the court to compel IBM to produce theremaining portions of the documents.

“IBM has never said that the requested, damning documents do notexist; it just refuses to produce them in an attempt to hide theman behind the curtain,” the former employee argues in a motionfiled Jan. 4.

IBM has been quietly firing people for years, Bloomberg hasreported, even as Chief Executive Officer GinniRometty publicly vowed to hire about 25,000 workers in the U.S.

Her hiring pledge, made in late 2016 on the eve of a summitbetween technology executives and then President-elect DonaldTrump, sparked outrage among current and former IBM workers, whovented on message boards and Facebook groups.

ProPublica last year published a wide-ranging story, based onsimilar documents, that argued IBM broke U.S. employment laws inits treatment of older workers.

Bloomberg retrieved the filings from the court's website beforethey were sealed at IBM's request.

IBM said the lawsuit “misses the point” since colleagues whowere older than the employee were retained on the team. “That'sbecause IBM makes its employment decisions based on skills andbusiness conditions — not age,” said Ed Barbini, an IBM spokesman.“In fact, since 2010 there is no difference in the age of our U.S.workforce, but the skills profile of our employees has changeddramatically due to our heavy investments in skills andretraining.”

IBM's workforce shrunk by 54,000 from the end of 2012 throughthe end of 2017 as the company let go of people in the U.S., Canadaand other high-wage jurisdictions in an effort to cut costs aftermissing out on the early stages of the cloud-computing andmobile-technology revolutions. Companies like Alphabet Inc.'sGoogle, and Microsoft Corp. have swept ahead in size, revenue andprestige, and Big Blue has struggled to catch up.

Many industries and companies in tech and beyond have beensending jobs overseas to take advantage of lower wages and to becloser to local markets. New York-based IBM now is reported to havemore employees in India than in the U.S.

The wave of layoffs has created a legion of disaffected workerswho say they were targeted for their age and the higher salariesthat come with decades of tenure.

ProPublica estimated that in the past five years alone, IBMeliminated more than 20,000 U.S. workers over the age of 40, about60 percent of its estimated total U.S. job cuts during thoseyears.

Since 2010, the company hasn't disclosed how many of itsemployees are based in the country, but at the end of 2017 IBMreported a total of 380,300 employees globally.

It's unclear who was involved in the creation of the documentand whether it reflects initiatives implemented by IBM.

Still, if authentic, the plans, which date from 2016 and areoutlined in the eight-page filing, fit with accounts of formeremployees interviewed over the past year, as well as reporting thatshows IBM has shifted thousands of jobs from the U.S. to cheaperlabor markets.

The title on one page says it was produced by the company's“Digital Business Group,” a unit responsible for integratingdigital technology throughout the company.

One slide, titled Hybrid Cloud – Talent Fall Plan Overview,details a strategy to “displace” jobs in major markets and hire inCosta Rica, India, Poland and Romania in a bid to increase “laborproductivity.”

Another slide titled “Early Professional Hiring” proposes a planto “shift headcount mix towards greater % of early professionalhires.” It's illegal in the U.S. to discriminate based on age whenit comes to hiring people over the age of 40.

IBM's alleged efforts to make its workforce younger have alreadycome under fire. The Equal Employment Opportunity Commission hasconsolidated complaints against IBM into a single, targetedinvestigation, according to a person familiar with it.

And lawsuits are cropping up against the company, including aclass-action suit filed by a lawyer who's taken on UberTechnologies Inc., Google and Amazon.com Inc. on behalf of theirworkers before.

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