The female plaintiffs in a long-running sex bias lawsuit challenging KPMG LLP‘s salary and promotion policies asked a federal court in New York Nov. 27 to grant them class status.

The purported class would be made up of approximately 10,000 female associates, managers, and directors employed by KPMG’s tax and advisory divisions from 2009 through the present. The motion simultaneously asks the court for final certification of a collective action under the federal Equal Pay Act.

The plaintiffs, led by Donna Kassman, say the female tax and advisory employees were systemically “paid less, and promoted less frequently, than their male peers,” according to the documents filed in the U.S. District Court for the Southern District of New York. KPMG was aware of the disparities but didn’t take any action to fix the issue, Kassman said.

But Kassman and her purported class members haven’t pointed to a single uniform KPMG policy or practice that would allow a court to sign off on a class certification, KPMG argues in its opposition brief to the court. KPMG says the pay and promotion decisions plaintiffs are attacking as systemic are in fact discretionary, decentralized, and don’t merit a class action attack.

Sanford Heisler Sharp LLP represents Kassman and the putative class. Sidley Austin LLP, Ogletree, Deakins, Nash, Smoak & Stewart P.C., and Constangy, Brooks, Smith & Prophete LLP represent KPMG.

The case is Kassman v. KPMG LLP, S.D.N.Y., No. 1:11-cv-3743, motion filed 11/27/18.