Google has been hit with a lawsuit by one of its project managers that alleges it goes so far with its internal confidentiality policies that it is breaching California labor laws. The lawsuit was filed by an employee who wishes to remain anonymous, going simply by John Doe in the document.

First reported on by The Information, the lawsuit specifically claims that Google runs an internal “spying program” to help combat employees leaking information to the media…

The suit, filed in the California Superior Court in San Francisco, alleges that Google’s policies violate labor laws in that they effectively prevent employees from discussing workplace conditions, wages, and potential regulatory and legal violations inside the company.

The policies stem from Google’s confidentiality agreement, which defines confidential information as “without limitation, any information in any form that relates to Google or Google’s business that is not generally known.”

On the other hand, Google’s Code of Conduct Policy states that confidential information consists of “everything at Google.” This policy restricts Google employees from posting any sort of opinions about Google online, even if they don’t contain confidential information. Additionally, it states that employees cannot converse with the press in any fashion.

Doe alleges that Google has put such a focus on stopping product leaks that one of its cofounders stated at an all-hands meet recently that anyone found to be leaking confidential information will be fired.

It doesn’t stop there, however. The lawsuit also describes an internal program at Google called “Stop Leaks,” which as you can probably guess from the name, carries a goal of stopping information related to Google from leaking online and/or via the media.

Here’s how Stop Leaks works, according to Doe’s lawsuit:

The Stopleaks program is managed through an internal website that includes a Chrome extension to facilitate the reporting of alleged “leaks” on the internet. Employees are required under Google policies to report “leaks” to Stopleaks. A violation of Google’s policies can result in termination.

Under its “Stopleaks” program, after a Googler submits a leak report to the Stopleaks site, Google’s “team of Stopleaks super sleuths investigate every leak. . . . The Stopleaks team researches the project/product that was leaked and aims to determine the leak’s origin. From here, [the Stopleaks team] often liaise with other cross-functional Google teams that may contribute additional context to the investigation.”

The purpose of Google’s “Stopleaks” program is to deter employees from asking questions (even of one another), or disclosing any information about Google in violation of their constitutional and statutory rights.

The central point of Doe’s case against Google is that the company must inform employees that they are allowed to discuss ongoings related to the company, in certain circumstances, with the press and government.

The lawsuit also alleges that Google’s director of global investigations, intelligence, and protective services, Brian Katz, falsely accused Doe of leaking information to the press, which is likely part of the reason for this lawsuit in the first place.

As for damages, The Information calculated the following:

Under the Private Attorneys General Act, Google could be fined up to $100 for each of the 12 alleged violations in the suit, multiplied by 65,000 employees. If an allegedly unlawful policy lasted for more than one pay period, the fine doubles to $200 per pay period, per employee, for up to a year. Based on a biweekly pay period schedule, if “Doe” prevails on every allegation in the lawsuit, the maximum fine would be $3.8 billion, with about $14,600 going to each Google employee.

Now, that’s very much a “worst case scenario” calculation, at least for Google. It’s unlikely that Doe will win every allegation he made.

You can read the full lawsuit here.