Defendants Apple Inc. (“Apple”), Alphabet, Inc. (“Alphabet”) (which is the parent company of Google LLC) (“Google”), Dell Technologies Inc. (“Dell”), Microsoft Inc. (“Microsoft”), and Tesla Inc. (“Tesla”) are knowingly benefiting from and aiding and abetting the cruel and brutal use of young children in Democratic Republic of Congo (“DRC”) to mine cobalt, a key component of every rechargeable lithium-ion battery used in the electronic devices these companies manufacture.

The young children mining Defendants’ cobalt are not merely being forced to work full-time, extremely dangerous mining jobs at the expense their educations and futures; they are being regularly maimed and killed by tunnel collapses and other known hazards common to cobalt mining in the DRC... 

The Plaintiffs here are a representative group of children who were forced by extreme poverty to leave school and pursue the only economic option in their region of the DRC -- become “artisanal” cobalt miners. They are officially referred to as “artisanal” miners to dress up the fact that this means they are working in a large informal sector of people, including young children...Miners are regularly maimed or killed when a tunnel collapses, and frequently, the bodies of those trapped in the darkness of rubble are never recovered... 

Defendants Apple, Alphabet, Dell, Microsoft, and Tesla are knowingly benefiting from and providing substantial support to this “artisanal” mining system in the DRC. Defendants know and have known for a significant period of time the reality that DRC’s cobalt mining sector is dependent upon children, with males performing the most hazardous work in the primitive cobalt mines, including tunnel digging...