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After a week of working together, Searle locked his office door and "went directly to Ong to grope her," according to the complaint, telling her they were “going to be lovers.” She rejected his proposal, and Searle apologized, paying her the promised $3,000. When he left for vacation the following month, Ong reported the assault to Hudin, the complaint states. Instead of reporting her allegations to upper management, “Hudin told Ong that she would protect her from Searle’s advances” and said Searle “has had sexual relationships with his students and others in the past in exchange for academic, monetary, or other benefits,” the complaint states.

When Searle returned from vacation, the workplace became “increasingly hostile and awkward,” the complaint states, as he pretended nothing had happened. Searle cut Ong’s salary in about half without explanation and continued to act inappropriately, according to the complaint. He openly watched pornography in front of her, the complaint states, and asked her to log into a “Sugar Baby, Sugar Daddy” website for him. The complaint says Searle also asked Ong to read and respond to his university emails, such as “flirtatious” correspondence with young women, “including UC Berkeley students and foreign students from Europe” who wanted to be his research assistant -- the position Ong held.

When Ong, who is Asian-American, brought up the topic of American imperialism, Searle responded “American imperialism? Oh boy, that sounds great, honey! Let’s go to bed and do that right now!” the complaint states.