Beginning in 1986, Paul Rangel was a sales professional for the pharmaceutical company Sanofi Aventis U. S. LLC (S-A). Rangel had satisfactory performance reviews until 2006, when S-A issued new "Expectations" guidelines with sales call quotas and other standards that he failed to meet. After two years of negative performance reviews, Rangel—who was then more than forty years old—was terminated as part of a nationwide reduction in force of all sales professionals who had not met the "Expectations" guidelines, including younger workers. Did S-A engage in age discrimination?

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