In 2015, plaintiff Dr. Daniel Chen, a postdoctoral fellow, was not renewed for the second year of his postdoctoral fellowship. He claimed that the University of California, Los Angeles, did not renew his postdoctoral fellowship because of his complaints of national origin discrimination and harassment. Chen sued the operator of the university, the Regents of the University of California, and his cytogenetics trainer, Jennifer Pelkey. Chen claimed that Pelkey was dismissive of him because he spoke with an accent. He also claimed that UCLA was tired of his complaints and, thus, made the decision to not renew his fellowship in retaliation for his complaints. Defense counsel contended that Chen’s “complaints” did not mention national origin discrimination or harassment. During trial, the defense highlighted all of Chen’s performance evaluations, which were completed at three-month intervals, reflecting Chen’s lack of progression in the fellowship program and his overall substandard performance. Defense counsel further pointed out that all of Chen’s faculty committee members consistently rated his performance as marginal, which allegedly supported UCLA’s decision to not renew the second year of Chen’s postdoctoral fellowship., Chen sought recovery of lost wages, and damages for his past and future emotional distress. He also sought recovery of punitive damages against Pelkey.