Former Regional Vice President Alleges Billion Dollar Tech Company, Celonis, Fabricated an Employee Stock Plan, Lured Him Into Employment, and Defrauded Him of $20 Million Before Firing Him


Shawn O’Connell filed a civil lawsuit yesterday in San Francisco County Superior Court against Celonis, a private software company that has been valued in the multi-billions.

O’Connell, a former Celonis Sales Manager, alleges in the legal complaint filed on March 14, 2022 that the company fabricated an “Employee Stock Plan” which it used to lure him from his lucrative former position at Salesforce. O’Connell further alleges that after working at the Company for over two years and ignoring his repeated requests for underlying stock equity documents and information, the Company fired him for whistleblowing. He also alleges it defrauded him out of nearly $20 million worth of company stock he believed his offer letter entitled him to. O’Connell’s complaint contends that Celonis terminated him in retaliation for his whistleblowing related to this and other conduct that O’Connell believed violated securities laws.

O’Connell’s legal complaint alleges that right before the Company fired him, it shared the truth: that the employee stock plan it represented to him at his hiring was never actually voted on or passed by its Board. According to O’Connell’s complaint, Celonis then told him he held just one-tenth of the stock he was originally promised—rather than the nearly $20 million it led him to believe he had earned. 

O’Connell also alleges he reported what he believed to be other violations of securities laws. As alleged, Celonis convinced its customers to spend millions of dollars on a recurring basis, in exchange for the opportunity for the client to invest in Celonis ahead of its anticipated IPO. O’Connell believed this tactic was designed to create the illusion of hyper-growth and distort Celonis’ valuation to the investing public, in violation of federal securities laws. 

O’Connell, a San Francisco Bay Area native and sales industry veteran, also alleges an employment claim for retaliation under the Fair Employment and Housing Act.

The complaint alleges that O’Connell discovered the purported equity discrepancy and reported possible securities violations within a period of a few months in 2021. Shortly after these events, the Company terminated him. O’Connell brings fraud, breach of contract, and civil employment claims for damages.

Tamarah Prevost, a partner at Cotchett, Pitre & McCarthy LLP pointed out further that the complaint alleges:

“This case is about corporate greed: after being lured away from a lucrative sales role, O’Connell’s complaint depicts an all-too-familiar story of a highly qualified employee who is retaliated against, terminated, and denied the stock he rightfully earned.”

Cotchett, Pitre & McCarthy engages exclusively in litigation and trials and has earned a national reputation for its dedication to prosecuting or defending socially just and economic fraud actions. To learn more about the firm, visit

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