The Non-Financial Ledger

Mark Goldstein spent most of his adult life building exactly the kind of expertise that a defense contractor would beg for. He worked at Nortel. He worked at America Online. He supported the Department of Homeland Security. He earned certifications in information security that exceed the clearance requirements Raytheon listed in its own job postings. He holds an active federal security clearance background. He has four decades of work in cybersecurity, risk management, and project management. He has a bachelor’s degree and an MBA.

And between 2019 and 2023, he applied to at least seven Raytheon positions for which he met every stated qualification. Seven times, Raytheon either rejected him outright or never responded at all. Seven times, not one interview. The complaint documents that Raytheon, on information and belief, hired substantially younger individuals for those roles who were not significantly more qualified than Goldstein.

What does it do to a person to watch a company publicly announce that it is desperate for workers with your exact skills, while that same company’s automated system is quietly discarding your application the moment it reads your graduation year? You are not competing on merit. You are not even being seen. You are being sorted out before a single human being looks at your name.

The complaint describes “stigmatic harm from seeing advertisements that indicate a preference for younger workers and discrimination against older workers.” That is lawyer language for something real: the experience of reading a job posting that tells you, in coded but unmistakable terms, that your experience is a liability and your age makes you invisible. Raytheon published those messages on its own careers website, on Indeed, on ZipRecruiter, on Monster. Any older worker in America who visited those platforms and searched for defense industry roles saw those postings. Countless qualified people, the complaint estimates tens of thousands, looked at those listings and correctly concluded that applying would be pointless.

They were right. The system was designed to tell them that.

Legal Receipts

The source document contains verbatim quotes from Raytheon’s own job postings, SEC filings, earnings call transcripts, and the EEOC’s Final Determination Letter. These are the words that cannot be walked back.

“***Great opportunity for current seniors in college or recent college graduates. If you are not a current college senior, or a recent college graduate, please visit our other opportunities at our rtx.com/careers and apply!***”

— Raytheon job posting, “Proposal Analyst I (early 2021 Start),” Req. No. 174644BR, as quoted in the complaint

• This posting does not merely list qualifications. It directly addresses older workers and redirects them away. It is written as an instruction to leave.
• This posting was published in 2021, the same year the EEOC issued its final determination that Raytheon’s ads violated the ADEA. The conduct continued without interruption.

“EEOC believes [Raytheon’s] job advertisements included language that violates the ADEA in that it indicated a hiring preference for applicants who are not in the protected age group. As noted in 29 U.S.C. 623[e] ‘When help wanted notices or advertisements contain any terms and phrases such as ‘age 25 to 35,’ ‘young,’ ‘college student,’ ‘recent college graduate,’ . . . or others of a similar nature, such a term or phrase deters the employment of older persons and is a violation of the [ADEA].'”

— EEOC Final Determination Letter, March 30, 2021, Exhibit A to the complaint

• The federal agency responsible for enforcing employment discrimination law looked at Raytheon’s ads and said explicitly: these violate the law. This is not an allegation. This is a government finding.
• The determination was issued in March 2021. The lawsuit, filed in June 2024, documents that Raytheon continued publishing the same substantive requirements for more than three years after this finding.

“The investigation revealed that [Mr. Goldstein] was denied the opportunity to be considered for the [Recent Graduate Positions] he had applied for because of his age, and not because he did not meet the minimum qualifications required for the jobs.”

— EEOC Final Determination Letter, March 30, 2021, Exhibit A to the complaint

• The EEOC’s own investigation concluded that Goldstein was qualified and was rejected because of age. This means the “qualifications” Raytheon cited were not the real reason. Age was the reason.
• This finding covers the specific positions Goldstein applied to in 2019. He then applied to additional positions through 2023. The tolling agreement and subsequent lawsuit extend this logic across a nationwide class.

“On labor availability, it’s a challenge. Everybody sees it, especially in the supply chain. And I think what’s interesting for — at RTX is we have hired 27,000 people in 2022. That’s about 3,000 a month since the beginning of the year. Our total headcount today is over 180,000. The challenge though is we would need about 10,000 more people. So a lot of work yet to do on labor.”

— Raytheon CEO and Chairman, Q3 2022 Earnings Call Transcript, October 25, 2022

• At the time this statement was made, Raytheon was actively maintaining the “Recent Graduate” hiring requirements that excluded workers aged 40 and over from entire categories of positions.
• The CEO acknowledged a shortfall of 10,000 workers. The complaint documents that Raytheon’s own SEC filings identified the lack of qualified engineers, skilled laborers, and security clearance holders as a specific threat to financial results. Older workers represent an established pool of exactly those workers. Raytheon was discarding them.

• This disclosure, made to investors, admits that qualified personnel are existentially important to Raytheon’s performance. The company simultaneously excluded an entire demographic of qualified workers from consideration.
• Nearly identical language appeared in the 2021 10-K. The 2022 10-K added that labor shortages had “negatively impacted, and may continue to negatively impact” financial results. The hiring practices that created this self-inflicted shortage were already in place and had already been flagged as unlawful by the EEOC.

Public Deception

Raytheon told investors and the public one thing while its hiring systems did another. The gap between its stated commitments and its documented conduct is not ambiguous.

• What Raytheon told investors: Labor shortages posed a serious and ongoing threat to financial performance; the company urgently needed qualified engineers, skilled workers, and security-clearance holders. What its hiring system did: Automatically screened out candidates with 40 years of relevant experience the moment their graduation year appeared in the application form.
• What Raytheon told the public: The company modified its job advertisement language after the 2021 EEOC determination, implying reform. What the complaint documents: Raytheon retained the same substantive requirement by shifting from explicit graduation-year language to caps on post-graduation work experience (no more than 12 or 24 months), achieving the identical age-filtering effect.
• What Raytheon’s job ads communicated: Positions were labeled as “entry level” opportunities with open merit-based competition. What the eligibility requirements enforced: A bachelor’s degree and 12 months or less of relevant work experience as the only stated qualification, which by design excluded nearly every worker aged 40 or older.

Profit-Maximization at All Costs

Raytheon pursued a documented strategy of building a younger workforce while simultaneously operating a $67-69 billion revenue enterprise. The complaint establishes that this strategy persisted through documented labor shortages, a federal discrimination finding, and years of legal pressure.

• Raytheon reported approximately $67.1 billion in gross revenues in 2023 and employed approximately 185,000 workers worldwide, with 70% in the United States. This is one of the largest defense contractors on the planet.
• In May 2023, the company’s former global head of talent acquisition confirmed that roughly 25% of all new hires were new or recent college graduates, a share that had grown in recent years. The complaint notes that among Recent Graduate Positions specifically, nearly all hires were under 40.
• Raytheon publicly promoted its “early career hiring” strategy to prospective investors as a feature of its workforce pipeline, framing the exclusion of experienced older workers as a competitive advantage, not a compliance failure.
• The company continued this strategy despite its own disclosures that labor shortages were threatening financial results and that it needed 10,000 additional workers. Excluding qualified applicants aged 40 and over from entire categories of positions worsened a problem Raytheon was paying to solve.

Legal Minimalism: The Letter but Not the Spirit

After the 2021 EEOC finding, Raytheon adjusted the wording of some ads. The adjustment was surgical and meaningless: the same workers who could not meet the old requirement could not meet the new one either.

• The ADEA, at 29 U.S.C. § 623(e), prohibits job advertisements that indicate a preference or limitation based on age. The regulation implementing it, 29 C.F.R. § 1625.4(a), specifically names “recent college graduate” as prohibited language. The statute’s purpose is to ensure workers over 40 can compete on equal terms for jobs they are qualified to perform.
• Raytheon’s response was to remove the words “recent college graduate” from some postings while adding a requirement that applicants hold a degree and have “12 months or less of relevant professional work experience (excluding internships).” Because approximately 95% of people over 40 have more than 12 months of work experience, the effect on older applicants was identical to the original language. The complaint documents this explicitly and provides multiple specific job postings from 2024 as examples.
• The complaint further alleges that Raytheon used automated screening systems that evaluated graduation year and cumulative work history to sort out applicants who did not meet the caps. A worker who graduated in 1980 would be rejected before any person at Raytheon reviewed their qualifications. The technical architecture of compliance was hollow.

How Capitalism Exploits Delay: Time as a Corporate Weapon

Raytheon’s response to federal findings of discrimination was not reform. It was a tolling agreement, a rebranding of job language, and three more years of the same conduct.

• Mark Goldstein filed his first EEOC charge on August 7, 2019. The EEOC issued its Final Determination on March 30, 2021: a gap of approximately 19 months before any official finding was in place. During those 19 months, the conduct continued.
• After the EEOC’s finding, the parties entered a tolling agreement on June 25, 2021. Tolling agreements stop the legal clock; they do not stop hiring. For three years while the agreement was in place, Raytheon continued posting the same functionally discriminatory job ads.
• Goldstein filed a second EEOC charge on July 11, 2023. He notified Raytheon of his intent to cancel the tolling agreement on May 7, 2024. The lawsuit was filed on June 11, 2024: nearly five years after the first charge.
• Throughout this period, any older worker who applied to a Recent Graduate Position, was rejected, and did not file a charge had no legal protection. The window for each individual claim under the ADEA is 300 days. Raytheon’s practices generated a continuous stream of potentially time-barred claims from workers who had no idea their rejection was unlawful.

Societal Impact Mapping

Public Health and Psychological Harm

The documented harm extends far beyond individual applicants. It reaches anyone who looked at a Raytheon job posting and understood what the language meant.

• The complaint documents “stigmatic harm from seeing advertisements that indicate a preference for younger workers and discrimination against older workers.” Stigmatic harm is a recognized legal category for a documented psychological reality: being told publicly that your category of person is unwanted causes measurable damage.
• Older workers who were deterred from applying were, the complaint alleges, “reasonably and correctly” deterred. The harm includes not just the lost job but the accurate understanding that the system was closed to them. That kind of systemic exclusion contributes to financial anxiety, reduced self-worth, and the documented mental health consequences of long-term unemployment in midlife and older adulthood.
• Goldstein applied to at least seven positions and was rejected without a single interview or any response in some cases. The complaint documents that he was also deterred from applying to dozens of additional positions he was qualified for, because he correctly understood that applying was futile. The combination of rejected applications and the recognition of futility describes a particular form of workplace exclusion that is difficult to escape and difficult to document.

Economic Inequality

Raytheon’s practices locked a protected class of workers out of a pipeline of federally-contracted, well-compensated jobs in a sector that was simultaneously reporting labor shortages.

• The specific job postings documented in the complaint ranged from approximately $53,000 to $113,000 in annual salary. These are not marginal positions. A Mechanical Engineer I posting from May 30, 2024 carried a salary range of $59,000 to $113,000. The only stated qualifications were U.S. citizenship and a bachelor’s degree with 12 months or less of experience. A 50-year-old mechanical engineer with 25 years of experience was categorically ineligible.
• Workers aged 40 and over denied access to these positions faced compounded economic disadvantage: lost salary, lost benefits, lost career advancement, and the ongoing cost of job searching in a market that was systematically signaling they were not wanted. The complaint explicitly lists “loss of income, benefits, and career advancement” among the documented harms.
• The class is nationwide. The complaint estimates tens of thousands of potential class and collective members. The aggregate lost wages across a class of that size, for positions in this salary range, across a period dating to October 2018, constitutes a substantial transfer of economic opportunity from experienced older workers to younger, less-experienced ones, on the basis of age alone.
• Defense contracting jobs frequently require security clearances. Workers with existing clearances, like Goldstein, represent an asset that is expensive and time-consuming for companies to develop. By excluding cleared, experienced workers from consideration, Raytheon also imposed costs on itself and, by extension, on government contracts funded by taxpayers.

The “Cost of a Life” Metric

This Is the System Working as Intended

This case is not the story of a rogue HR department or a policy that slipped through. It is the story of a documented, deliberate, company-wide strategy that survived a federal finding, a legal settlement framework, and years of public labor shortage disclosures without changing its substantive outcome.

• Raytheon told its investors that attracting younger workers was a priority and reported to them on its “early career hiring” pipeline as a business strength. The exclusion of older workers was a feature being sold to the market, not an accident being corrected.
• The EEOC issued a formal finding of violation in March 2021. Raytheon’s legal response was a tolling agreement, which protected the company from time-barred claims while the practice continued. The clock stopped for Goldstein’s lawyers. It kept running for every new older applicant who received an automated rejection.
• The complaint documents that Raytheon’s own SEC filings from 2020 through 2022 identified the labor shortage as a material financial risk. The company disclosed to its investors that it needed qualified engineers and clearance holders. It was simultaneously filtering out the most experienced engineers and clearance holders in the applicant pool. The system that produces this outcome is one in which investor disclosures are treated as legal obligations and discrimination law is treated as a negotiation.
• The individual economic harm to each class member is, as the complaint notes, “unlikely to be large enough to warrant pursuing individual litigation.” That is precisely how systemic discrimination of this kind persists. Each individual rejection is too small to litigate. The cumulative exclusion is enormous. The gap between those two scales is where the practice lives.

What a Legitimate Fix Looks Like

Editorial analysis. The following recommendations are based on the specific failure modes documented in the source complaint and are presented as editorial, not as findings of the complaint itself.

The core structural failure this case exposes: federal anti-discrimination law for older workers has no real-time enforcement mechanism. A company can receive a finding of violation, enter a tolling agreement, reword its ads while preserving their effect, and continue for years before facing a court. The ADEA’s private right of action depends entirely on individual plaintiffs having the resources and resolve to sustain a multi-year legal process.

What Now?

This case is active in the United States District Court for the District of Massachusetts, Case No. 1:24-cv-11525. RTX Corporation is the defendant. The company’s leadership and board overseeing the hiring practices described in this complaint hold those roles at a company that bills itself as a trusted partner of the United States government.

Watchlist: Oversight Bodies

• EEOC (Equal Employment Opportunity Commission): The agency that already found Raytheon violated the ADEA in 2021. File age discrimination charges at eeoc.gov. If you are 40 or older and were rejected for a Raytheon “New Grad” or “entry level” position, you may be a class member.
• Massachusetts Commission Against Discrimination (MCAD): State enforcement body with jurisdiction over employers operating in Massachusetts, where Raytheon operated its headquarters through June 2022.
• Virginia Office of Civil Rights (OCR): State enforcement body named in the complaint as a jurisdiction where charges have been filed.
• SEC (Securities and Exchange Commission): Raytheon’s disclosures to investors about its workforce and labor shortage risks are public record at sec.gov. If Raytheon continued discriminatory practices that materially worsened the labor shortages it was disclosing as financial risks, that intersection raises investor protection questions worth monitoring.
• Department of Defense Inspector General: Raytheon is a major defense contractor. Federal contractors are subject to equal employment opportunity requirements as a condition of contracting. Complaints about contractor non-compliance can be submitted to the DOD IG or the Office of Federal Contract Compliance Programs (OFCCP) within the Department of Labor.

Mutual Aid and Organizing

• If you are a worker aged 40 or older who applied to Raytheon/RTX positions labeled “New Grad,” “Recent Graduate,” or with a “12 or 24 months or less of experience” requirement since October 2018, contact the legal team behind this case: AARP Foundation Litigation (aarp.org/legal), Outten and Golden LLP, or Peter Romer-Friedman Law PLLC. Your experience may qualify you as a class member.
• Share this case with workers in your network who are in engineering, cybersecurity, project management, or defense contracting. The complaint estimates tens of thousands of potential class members. Many of them do not know they were rejected for an illegal reason.
• Organized labor in the defense sector should include ADEA compliance as a bargaining and monitoring priority. Age discrimination in hiring is structural and systematic in ways that individual grievances cannot address alone. The infrastructure to fight it at scale already exists in this case.
• If you are a hiring manager, HR professional, or software engineer at any large employer who maintains automated screening systems with graduation-year or experience-maximum filters, document what you see. Whistleblower protections under the ADEA and state analogs exist. Legal counsel can advise on scope and process.