Everything below comes from documents on the public docket in Born v. AbbVie, Inc., No. 1:25-cv-12737 (N.D. Ill.) — the complaints, the court’s order, AbbVie’s motion, and the plaintiff’s opposition. They are allegations. AbbVie disputes them and has asked the court to dismiss the case. No court has decided whether any of it is true. The paragraph citations allow journalists to check against PACER docket entries. 44 and counting, as of 8/27/26.
AbbVie’s lawyers have a phrase for what Kathryn Born filed against them: “vague references to ‘fraud.'” Born has a phrase for what AbbVie’s lawyers filed back: they argue “about each brick, and never about the wall.”
Fine. Here are the bricks. In order.
2018–2021: The Two-Person ARCH Adoption Team
AbbVie hires Born as a contractor in June 2018 and as an employee in February 2019, an instructional designer with good reviews. In November 2021 it promotes her to Training and Communication Manager for ARCH — the AbbVie Research and Convergence Hub — a software platform built to “accelerate and improve scientific discovery” for the roughly 12,000 chemists, biologists and data scientists in R&D. AbbVie describes it internally as infrastructure “[f]or everyone in R&D” and, per the complaint, invests “tens of millions of dollars” in it. (SAC ¶¶ 6–7, 11; Dkt. 24 ¶ 9.)
Born’s job is adoption: getting scientists to use the thing. She and her manager are a dedicated unit with the literal title of “ARCH Adoption Team.” It has two people. From November 2021 on, they review the platform’s usage analytics every month. (SAC ¶¶ 8–9.)
Brick one: the person whose job was to count the users could see the user data.
Early 2022: Twenty
In early 2022, according to the complaint, the number of regular ARCH users is approximately twenty. (SAC ¶ 19.)
In March 2022, Born reports to her manager that the platform does not do the self-service data querying described in AbbVie’s own internal materials. She is told, per the February 2026 complaint, to keep producing training materials “since there was nothing wrong with the software.” She produces the training materials. (Dkt. 24 ¶¶ 10–12.)
That same year, AbbVie’s Vice President of R&D Information Research, Phil Hajduk, presents ARCH adoption figures to the company’s most senior scientific officer. The Powerpoint slide says 2,000 users.
If it’s around twenty regular users; why 2,000 on the slide? The complaint’s explanation: the slide number is a running total of everyone who has ever logged in since the platform launched in 2019. (SAC ¶ 19.) Brick two.
2022–2024: The Twenty-Five-Dollar Gift Card
Rather than fix the platform, Born’s manager allegedly directs her to hand out $25 gift cards — “AbbVie Excellence Awards,” a program whose formal criteria reserve it for performance “beyond ordinary job duties” — as an incentive to use ARCH. The February complaint alleges the awards went “to the same group of approximately 20 individuals for multiple years for routine activities, such as entering dummy data,” at roughly $20,000 a year, and that this was “used to artificially inflate ARCH adoption metrics.” (Dkt. 24 ¶¶ 14–17.)
Twenty regular users. The goal was 14,000. Brick three.
2023: The Four-Hour Miracle
This is the famous one. ARCH wins a 2023 Bio-IT World Innovative Practices Award. AbbVie’s story, told at the conference, in an internal executive video, on a podcast, and eventually in an August 7, 2024 Bio-IT World article titled “Howard Jacob on How AbbVie’s ARCH is Unlocking Major Opportunities,” is that Vice President Howard Jacob and Phil Hajduk used ARCH to find “two drugs in the market that could potentially treat” a patient with Carney complex, a rare genetic disease, “in only four hours.” (SAC ¶¶ 13–14.)
Born’s job is to turn wins into training. So she tries to build a demo showing a scientist how to reproduce the four-hour miracle in the software. She can’t. AbbVie, per the complaint, cannot produce “a simple video showing the steps.” So she asks Hajduk — the man named in the article — to walk her through it.
Hajduk, the complaint alleges, tells her in a 1:1 in-person meeting at the Abbot Labs campus, when Born beseeched him to make a 15-minute video showing how he did it, he admitted the platform “isn’t there yet,” and that he did the analysis himself, “using conventional online scientific research, not through ARCH.” Born, “stunned,” leaves his office and tells a colleague: “We need to drop it and never bring it up again.” No corrected account is ever published. The award stays on the shelf. (SAC ¶ 18; Dkt. 21 ¶ 20.)
Brick four — the one the whole wall is named after. But keep counting.
Late 2023: Generative AI, Embedded
In summer 2023, a completely different technology group at AbbVie installs a large language model API based on Open AI’s ChatGPT model 3.5. It’s an overnight sensation and no impact to the ARCH’s numbers. Called Go/AI, it was not ARCH, it had no adoption team at all, and it took about two million prompts in its first ten months on word of mouth. (SAC ¶ 21.) So AbbVie knew what real adoption looked like. It just wasn’t happening on the platform with the award.
On November 27, 2023, AbbVie’s own website announces that “the company’s generative AI platform is being embedded into the ARCH, creating an even more powerful tool,” potentially reaching “the company’s 14,500 employees in R&D.” (SAC ¶¶ 12, 15.)
According to the complaint, ARCH’s search was, and remained, an old-fashioned keyword queries javascript software interface, returning giant downloadable tables. At developer meetings, users kept asking for natural-language answers, and the ARCH team kept saying it had no plans to build that. The only generative-AI thing with “ARCH” in the name was “Ask ARCH,” a separate tool built by a different AbbVie team over a limited slice of material. As of September 2025, the complaint alleges, nothing generative had been embedded in ARCH. (SAC ¶ 21.)
Meanwhile PubMed, the free government journal database, launched natural-language search of the scientific literature in 2024, “rendering a core ARCH feature obsolete by a public tool.” (SAC ¶ 21.) Brick five: the tens-of-millions-of-dollars platform, lapped by a free AI journal search tool and an outdated ChatGPT API.
2024: The Slide Says 4,000, Then 6,000
The 2023 year-end figure presented to leadership: approximately 4,000 users. The 2024 year-end figure: approximately 6,000. Born personally hears Hajduk say, at a recorded quarterly meeting, “Thousands of people use the ARCH every month.” (SAC ¶ 16.)
The complaint alleges nobody ever checked — no data scientist, no independent reviewer. Born “specifically looked into why, and confirmed no one did.” It also alleges that after her manager left in mid-2024, the activity of the hundreds of developers and vendors paid to build and test the platform, previously excluded from the count because it wasn’t scientists, started getting counted as users. (SAC ¶ 19.) Brick six.
2024: The Jira Tickets
ARCH was an interface to the data lake (in simplest terms- you could search for a gene, molecule or health condition) – in addition, is/was represented as self-service “ARCH data lake”, which promised access to about 200 expensive datasets. What scientists actually get, per the complaint, is “a runaround and a series of unresolved Jira support tickets,” after which, following “weeks of delay,” they “routinely gave up.” Thousands of scientists are told to go to ARCH for their data and can’t get it, “generating a large volume of documented tech support tickets.” (SAC ¶ 20.) (Appox 8,000 Jira tickets.) The support tickets are, in other words, the adoption metric nobody put on a slide. Brick seven.
May 2024: Report Up, Get Moved Sideways
Born tells Brian Martin, AbbVie’s Chief AI Product Owner and her manager’s boss, about her concerns — and that she has already taken them to HR with documentation. The next day, per the February complaint, Martin informs Born and her manager that they are being transitioned off ARCH and onto “Convergence,” a parent initiative under a different executive. Six weeks later the manager leaves and is not replaced. Born’s next manager lasts about three weeks. The one after that, about ten months. (Dkt. 24 ¶¶ 18–20; SAC ¶ 10.)
Four managers in a little over a year. Brick eight.
July 2024: HOLLY
Born builds something on her own, based on GenAI research outside of work: HOLLY, an AI card catalog that maps a scientist’s question to the ARCH tool that might answer it. She sends a video demo to Jacob, Bawa, Martin and Hajduk. She receives, per the complaint, “no substantive response,” and is then instructed to stop working on it and go back to training people on the existing platform. (Dkt. 24 ¶¶ 22–23.) Brick nine: the adoption manager built an AI searchable catalog, and was told to put it away.
March 2025: “Cooking the Books, That Is Ethics”
Born sits down with Tina Neely, an HR manager in Employee Relations, and reports that misleading statements have been made about ARCH’s adoption and capabilities — thousands of “users” that were really five years of cumulative logins, never verified. The two of them sort out jurisdiction. Born’s formulation, in words or substance: “if it is bullying, that is HR, and if it is cooking the books, that is ethics.” Neely: “that is correct.” (SAC ¶ 24.)
The same month, per the original complaint, a data analyst writes to HR that Born should be fired — because she was the one telling the team that his dashboards “had been unstable and largely inoperable for over two years.” (Dkt. 1 ¶ 25.) Brick ten: the person reporting the broken thing gets reported.
July 2025: The Ethics Case Opens. The Fourth Manager Arrives.
On July 7, Born reports to Neely in writing that, among other things, a group in the organization has been artificially inflating its usage analytics by rewarding employees for using its tools. Neely replies, in writing, that she is sending it “to our OEC partners as it appears that you are mentioning concerns that are not in compliance.” The Office of Ethics and Compliance opens Case No. abb-68a3-3a1b-8820. (SAC ¶¶ 25–26.)
Around the same time, Born’s third manager leaves, and she begins reporting to Dmitriy Kolodin, a vice president. In their first one-on-one, she tells him an ethics complaint has been filed about ARCH, that it implicates senior leadership including Howard Jacob, and that she is the one who filed it. (Dkt. 24 ¶¶ 27–28; SAC ¶ 29.) Brick eleven, and the start of the last ninety days.
August 8, 2025: The PIP
Kolodin places Born on a performance improvement plan, copied to Howard Jacob and to Dina Mutawi in HR. The PIP is a remarkable document, because the complaint quotes it. Among Born’s cited failings: “You have repeatedly and incorrectly mentioned in meetings and in your email (April 30th) that we are not willing to dedicate resources to make ARCH usable and that sometimes there are only 20 people who use ARCH, per month.” She is directed to “[r]efrain from spreading misinformation.” And in the same document, Kolodin puts ARCH’s real number in writing: “>400 unique user/month.” (SAC ¶¶ 31–32.)
Four hundred. Not thousands. The performance plan disciplining her for saying the number was small contains a small number. Brick twelve.
The PIP also faults her for posting outdated training materials. Per the complaint, a member of the ARCH team had told her in a Teams message to post exactly those materials because the new ones weren’t ready; the screenshot is on the laptop AbbVie kept. (SAC ¶ 33.) And it bars her from applying for other jobs without HR approval — at the very moment, the complaint alleges, that the head of AbbVie’s Enterprise AI Learning Program has put her on the company-wide AI Training Committee and a commercial-training leader wants her to form a committee on cost savings she identified. (SAC ¶ 34.)
August 18–20, 2025: Everyone Is Confused
August 18: Born identifies herself in writing to leadership and HR as an “internal whistleblower” who has consulted counsel. Jacob is copied. (SAC ¶ 30.)
August 19: Born files a further report through the OEC hotline, “Speakfully,” reporting that the PIP is retaliation. The same day, Mutawi confirms in writing that Born “must show progress on the expectations outlined in the PIP by September 22, 2025.” (SAC ¶¶ 27, 35.)
August 20: Jacob — the executive from the Bio-IT World article, copied on the PIP — replies. Per the February complaint, he indicates “that he thought that the ethics investigation had closed and that BORN’s concerns were really a Human Resources issue.” Per the July complaint, he writes that “[t]he performance process is separate and apart from any concerns that you have reported.” He then forwards Born’s email to Christina Gabriel, the ethics investigator, who reads portions of it back to Born at their meeting the same day. (Dkt. 24 ¶¶ 35–36; SAC ¶ 30.)
So: HR thinks it’s ethics. The VP thinks it’s HR. Ethics is reading the VP’s forwarded email aloud to the whistleblower. In a meeting Born says, “I can’t believe that ethics and HR won’t talk to each other, I can’t believe that the anti-retaliation training is a total sham.” Brick thirteen.
September 4–12, 2025: “Well Aware”
September 4: Born emails Kolodin a completed, reviewed training document — a PIP deliverable. He does not acknowledge it. He does, per the February complaint, tell her he is “well aware of the problems with the ARCH.” She asks to transfer to the group running the enterprise AI training committee she has been invited to join. He refuses, and won’t say why. (Dkt. 24 ¶¶ 38–40.)
September 9: Born submits a two-year blueprint for her AI system, an “AI Ad Hoc Knowledge Graph.” Kolodin’s response, per the original complaint: “he did not understand this blueprint.” (Dkt. 1 ¶¶ 35–36.)
September 12: Mutawi requests a video call. Kolodin is on it. Born is terminated, effective immediately — ten days before the September 22 deadline HR put in writing, with the ethics case still open. Born asks why Mutawi isn’t talking to Gabriel about the ethics complaint. Brick fourteen.
After-Termination AI Champion
After her termination, the head of the AI learning program circulates a list of AbbVie’s AI “champions” to the training organization of more than 2,000 people. Born is on it. (SAC ¶ 34.) Brick fifteen.
The Litigation Bricks
October 17, 2025: Born sues, with a lawyer. January 2026: she files her own amended complaint. February: another. July 8, 2026: Judge Lindsay C. Jenkins dismisses it — not because the story is implausible (the court takes it as true at this stage) but because Born mentioned Sarbanes-Oxley, which has its own whistleblower remedy, and Illinois common law won’t duplicate one. Leave to refile. (Dkt. 33.)
July 13: Born refiles under the Illinois Whistleblower Act, sixteen pages, every brick above with a paragraph number.
August 19: AbbVie moves to dismiss again. Two arguments: the Bio-IT World article is a “third-party” statement, and Born never named the law she thought was being broken. In its statement of facts, AbbVie’s memorandum also disputes Born’s user allegations “despite 400 unique users per month equating to approximately 4,800 users per year.” Eight pages later, the same memorandum states: “Users per month do not equate to users per year.” (Mem. at 3, 11.)
August 27: Born’s opposition points out that the article is titled with an AbbVie vice president’s name and built on his account — “the words are the employer’s; the magazine is only the megaphone” — and that AbbVie’s own 4,800 arithmetic “reproduces the very conflation of cumulative and current figures that Plaintiff reported internally.” It also notes what the motion doesn’t argue: not that she didn’t report, not that they didn’t know, not that she wasn’t fired early. “It makes no argument about causation at all.”
The Wall
A complaint, the opposition argues, must be read “as a whole, not parsed piece by piece.” One optimistic sentence could be puffery. One inflated figure could be a mistake. One mis-credited discovery could be sloppiness. But fifteen bricks, all backed by evidence — that is a wall.
The court has not ruled.
Media Contact: Kathryn Born Dusoma Foundation: AI for Humanity kathryn.born@dusoma.org
Press release and full opposition brief (15 pages) here: https://dusoma.com/abbvie-ai-whitewashing-whistleblower-case-kathryn-born/