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RENSSELAER POLYTECHNIC
INSTITUTE,
Defendant.
Plaintiffs, by and through their undersigned attorneys, as and for their class action
I. INTRODUCTION
(“RPI” or “Defendant”) to recover tuition and fees paid by students for an on-campus academic
experience and related on-campus services which Defendant has failed to deliver as promised.
has moved all class instruction completely online, resulting in Plaintiffs being denied the
educational instruction, facilities and services that they bargained and paid for. Defendant,
however, continues to charge Plaintiffs tuition and fees for the undelivered services without any
refund or adjustment. Defendant’s conduct has resulted in injury to Plaintiffs, constitutes a breach
of Defendant’s contractual duty owed to Plaintiffs, and it would be against equity and good
3. As a result of the above, Plaintiffs and the putative class are entitled to legal and
equitable relief, including, but not limited to, monetary damages, disgorgement of sums paid,
injunctive relief, and the costs, disbursements, and reasonable attorneys’ fees of this action.
II. JURISDICTION
4. This Court has subject matter jurisdiction pursuant to the Class Action Fairness
Act, 28 U.S.C. § 1332(d) because this is a class action involving more than 100 putative class
members, some of whom are citizens of states diverse from Defendant, and the amount in
5. This Court has personal jurisdiction over Defendant because it is organized and
incorporated under New York law, maintains its principal place of business in this district,
regularly and systematically transacts business in this district, and the wrongful conduct
resides in this district and a substantial part of the events or omissions giving rise to the complaint
occurred in this district, and Defendant is subject to personal jurisdiction in this district.
III. PARTIES
Commonwealth of Massachusetts.
enrolled at Rensselaer Polytechnic Institute and was charged tuition and fees by Defendant for the
Connecticut.
2
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10. At all relevant times, Mr. Habicht was an undergraduate engineering student
enrolled at Rensselaer Polytechnic Institute and was charged tuition and fees by Defendant for the
corporation and private research university incorporated under the laws of the State of New York
with a principal place of business located at 110 8th Street, in the City of Troy, County of
12. RPI describes its organizational mission as being to “educate[] the leaders of
tomorrow for technologically based careers.” See Rensselaer Polytechnic Institute 2017 IRS Form
13. In 1999, under the leadership of President Shirley Ann Jackson, RPI developed and
adopted the “Rensselaer Plan” (the “Plan”), a foundational, university-wide, administrative policy
devoted to increasing the university’s standing and improving the educational experience offered
to its students.
14. Under the Plan, RPI developed and subsequently marketed to its prospective and
current students a unique academic experience fundamentally centered around an in-person, on-
15. The Plan, which was updated in 2013, contains, among other things, specific
Among the most prominent of these We Will Statements is the university’s commitment to “[o]ffer
a complete student experience, highlighted by: Clustered Learning, Advocacy, and Support for
Students (CLASS).” A copy of the Plan, as revised in 2013, is annexed hereto as Exhibit “A.”
3
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16. A fundamental tenet of the CLASS program as set forth in the Plan is the
importance of the on-campus experience and related on-campus services to the educational
experience at RPI which is embodied in its emphasis on “Clustered Learning.” Exh. “A”, at p. 4.
17. At all relevant times, RPI marketed its CLASS program to current and prospective
students as “a bold, comprehensive, and holistic residential college model that provides
unparalleled developmental education and support in every sphere of student life—from our
revitalized residential settings to our leading-edge classrooms and laboratories.” Id. at p. 10.
18. In describing the value of the CLASS program to students, RPI advised prospective
students on its website and in other forums that “CLASS provides a programmatic framework for
strengthened counseling, unique co-op experiences, academic skills building, cultural exposure,
leadership opportunities, community building, and global engagement” and notes that “Many of
these activities originate within the residential setting.” Id. The university further described the
CLASS program as one of its “unique strengths” that differentiates it as an institution of higher
19. RPI promoted the value provided by its on-campus experience and related on-
campus services to prospective students throughout the Plan and elsewhere in its marketing
materials to current and prospective students. For example, on its website, it promised that “[w]ith
over 475 residential programs annually, students will have the opportunity to socialize with hall
residents and the campus community while increasing their knowledge of Multicultural
Sophistication, Intellectual Agility, and a Global View.” Student Living and Learning, Rensselaer
commons/living-learning.
4
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20. On its website, RPI further marketed the value of the CLASS program to
prospective and current students in an informational video that featured students engaged in a
wide-range of on-campus events including working in laboratories, using the athletic facilities,
and socializing in student common areas, and featured students and faculty attesting to the
transformative impact of the on-campus residential academic experience. See CLASS (Clustered
Learning, Advocacy, and Support for Students), Rensselaer Polytechnic Institute Website, (last
21. RPI promoted the importance of the on-campus residential academic experience to
its CLASS program, which it described as “Residential Clustering,” on its website, stating:
Id.
5
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22. In the Plan and as part of the CLASS program, RPI also promised that “we will
. . . [p]rovide for our students an inclusive community, within a residential college model, that
supports them in their personal growth and success.” Exh. “A”, at p. 20.
23. RPI further acknowledged the crucial importance of on-campus residential and
recreational facilities to the student experience in the Plan, noting that “[r]esidential and
recreational facilities for our students must be inviting and support a robust living/learning
24. In fact, RPI deemed the on-campus, residential experience to be so critical to the
overall student experience and its academic product that it mandated that all first and second year
students, transfer students, and rising undergraduate juniors participating in the mandatory “The
Arch” summer semester live on campus and pay fees for room and board.
25. In justifying this on-campus residential mandate, RPI stated on its website that
“[l]iving on campus is a critical component of the CLASS (Clustered Learning, Advocacy, and
Support for Students) experience. It provides students with the opportunity to live, learn, and
experience Rensselaer and the local Troy area with members of their cohort.” Student Living and
Learning, Housing Requirement, Rensselaer Polytechnic Institute Website, (last accessed May 3,
2020), https://sll.rpi.edu/residential-commons/housing-requirement.
26. The Arch requirement for rising undergraduate juniors was promoted by RPI in the
Plan and elsewhere as another crucial and fundamental component of its academic product.
“During The Arch, students remain on campus for the summer after
their sophomore year, taking junior-level classes, and receive
focused attention from professors at this pivotal point in their
academic progression. Then, students leave the Troy campus for a
semester during the traditional junior year—either fall or spring—
to pursue their passions in the form of co-ops, internships, civic
6
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The Arch, What is the Arch?, Rensselaer Polytechnic Institute Website, (last accessed May 3,
2020), https://info.rpi.edu/arch/what-arch.
28. In essence, The Arch is a mandatory summer semester for rising undergraduate
juniors that takes the place of a traditional semester during their junior year. After completing The
Arch requirement, students then take part in a “Semester Away” during their junior year in which
they are encouraged to seek out internships and other forms of experiential learning away from the
RPI campus.
29. Students are charged tuition and fees for their Arch Semester in the same manner
30. Indisputably, the Plan has achieved transformational results for RPI, and the
31. In this regard, in its most recently available tax return for the year ending June 2018,
RPI reported annual revenue of $591,700,082 and total assets worth over $1.5 billion. See Form
32. Upon information and belief, the success of the Plan and its importance to the
university is also reflected in the compensation paid to the school’s executive president, Dr.
Shirley Ann Jackson, who is reported to be the third highest paid college official in the nation
with total compensation of over $5,000,000 annually. See Bauman et al., Executive
Compensation at Public and Private Colleges, THE CHRONICLE OF HIGHER EDUCATION, Jan. 14,
2020, https://www.chronicle.com/interactives/executive-compensation#id=table_private_2017
7
Case 1:20-cv-00498-TJM-DJS Document 1 Filed 05/04/20 Page 8 of 17
observed by state and federal authorities to have spread to the United States and the State of New
York.
34. On or about March 10, 2020, RPI became one of the first colleges in New York’s
Capital District to announce that it was cancelling all in-person instruction and would be
35. Thereafter, RPI announced that it would be taking immediate action to bring
a. Directing Plaintiffs and all other students living on campus to vacate their on-
b. Prohibiting Plaintiffs and all other students from accessing any on-campus
36. Upon information and belief, the fair market value of online academic instruction
is substantially less than the fair market value of the on-campus academic experience and related
37. Nevertheless, RPI thereafter announced to its students that “Rensselaer will not be
adjusting tuition for the spring semester 2020. Class are continuing through remote instruction.”
Frequently Asked Questions, Division of Student Life, Office of the Vice President, Rensselaer
8
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faq-students
38. RPI also subsequently announced that the above-mentioned restrictions would
apply not only to the Spring 2020 semester, but to the upcoming Summer 2020 Arch semester as
well.
39. RPI conceded on its website that “one intent of The Arch program is for students
to live and learn on campus together” and that “[w]e realize that we cannot completely replace the
of Student Life, Office of the Vice President, Rensselaer Polytechnic Institute Webpage, (last
40. On or about April 3, 2020, RPI began providing instruction to its students solely
41. As a result of the restrictions put in place by Defendant, students who were charged
tuition for the Spring and/or Summer 2020 Arch semesters have and will be deprived of an on-
campus academic experience and related on-campus services that were promised to them by
on learning;
athletic facilities;
9
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e. The ability to engage in in-person interaction with other students, faculty, and staff;
and
42. Despite its inability to deliver the on-campus academic experience and related on-
campus services it promised to students, RPI has failed and refused to refund or adjust any portion
of the tuition paid by Plaintiffs or, upon information and belief, any of its students for the Spring
43. Additionally, RPI has further failed to refund or adjust fees charged to Plaintiffs or,
upon information and belief, any of its students, for the Spring 2020 and Summer 2020 Arch
semesters in an amount that equitably compensates students for their reduced ability to utilize the
services for which those fees were charged, including, but not limited to student activity fees,
health center fees, and fees for individual clubs and activities.
44. In addition, RPI has refused to reduce or adjust the tuition and fees charged for the
Summer 2020 Arch semester notwithstanding its inability to provide the promised on-campus
45. RPI’s failure to reduce or refund the tuition and fees charged for the Spring 2020
and Summer 2020 Arch semesters has resulted in Plaintiffs and other similarly situated students
46. In effect, RPI has sought to reduce the financial burden it faces as a result of the
47. Upon information and belief, RPI has engaged in these acts and omissions at the
expense of its students despite having accepted millions of dollars in federal aid under the
10
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Coronavirus Aid, Relief, and Economic Security (CARES) Act intended to replace revenue lost as
V. CLASS ALLEGATIONS
48. Plaintiffs repeat and reassert each of the preceding paragraphs as though fully set
49. Plaintiffs seek class certification pursuant to Fed. R. Civ. P. 23 (a), (b)(2) and (b)(3)
50. Upon information and belief, the scope of the class may be further refined after
51. The exact number of members of the class, as identified above, is not known to
plaintiffs, but upon information and belief, exceeds 7,000 persons and is sufficiently numerous
52. The members of the putative class are mutually and commonly aggrieved and the
relief sought is common to the entire class and, if granted, would commonly benefit the entire
class.
53. There are numerous questions of law and fact common to plaintiffs and the class,
including:
11
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a. Whether Plaintiffs paid tuition to Defendant for the Spring 2020 and/or Summer
b. Whether Plaintiffs paid fees to Defendant for the Spring 2020 and/or Summer
d. Whether Defendant was unjustly enriched by Plaintiffs’ payment of fees for the
to retain the full unrefunded amount of tuition paid by Plaintiffs for the Spring
to retain the full unrefunded amount of fees paid by Plaintiffs for the Spring
contract.
54. Common questions of fact and law predominate over any questions affecting only
individual members of the class, including but not limited to the alleged acts and omissions and
55. Plaintiffs’ claims herein are typical of the claims of the class, in that the claims of
all members of the class, including Plaintiffs, depend on a showing of the acts and omissions of
12
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56. Plaintiffs will fairly and adequately protect the interests of the respective class
members in that plaintiffs have such a plain, direct, and adequate interest in the outcome of the
controversy to assure the adequacy of the presentation of the issues involved herein. Plaintiffs
57. Plaintiffs have retained competent counsel with substantial experience litigating
58. Plaintiffs and their counsel are committed to vigorously prosecuting this action on
behalf of the class and have the financial resources to do so. Neither Plaintiffs nor their counsel
59. Class action treatment is superior to other available methods for the fair and
unreasonably expensive in light of the probable recoverable damages, burdensome upon the court,
61. Absent class certification, the claims of infant class members may never be timely.
62. Plaintiffs repeat and reassert each of the preceding paragraphs as though fully set
with an on-campus academic experience and related on-campus services during the Spring 2020
and/or Summer 2020 Arch semesters in consideration for the payment of certain tuition and fees.
13
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64. Plaintiffs accepted Defendant’s offer and tendered the agreed upon consideration
65. Defendant thereafter failed to provide the agreed upon on-campus academic
experience and related on-campus services in breach of the parties’ contract and in violation of the
parties’ agreement.
66. Defendant failed to act fairly and in good faith in its contractual dealings with
Plaintiffs.
67. Plaintiffs have been damaged by Defendant’s breach of contract by, among other
things, being deprived of the full value of the bargained for on-campus academic experience and
related on-campus services and by the future diminution of the value of their academic degree and
earnings.
including, but not limited to, reimbursement of tuition, fees and other expenses, in an amount to
69. Plaintiffs repeat and reassert each of the preceding paragraphs as though fully set
70. At all times relevant, defendant Rensselaer Polytechnic Institute made a clear and
71. The promises made by Defendant are incorporated into the Plan, which
14
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the Plan.
73. Among the most prominent of the We Will Statements is Defendant’s commitment
to “[o]ffer a complete student experience, highlighted by: Clustered Learning, Advocacy, and
74. It was reasonable and foreseeable that students would rely on Defendant’s promise
to provide students with an on-campus academic experience and related on-campus services.
other things, being deprived of an on-campus academic experience and related on-campus
services.
76. Defendant should be equitably estopped from retaining the full amount of the
tuition and fees paid to Defendant by Plaintiffs for an on-campus experience and related on-campus
services.
determined upon the trial of this action, including, but not limited to, reimbursement of tuition,
fees and other expenses, and such other and further relief as this Court deems just and equitable.
78. Plaintiffs repeat and reassert each of the preceding paragraphs as though fully set
79. Plaintiffs paid tuition and fees to defendant Rensselaer Polytechnic Institute for an
on-campus academic experience and for related on-campus services during the Spring and/or
15
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80. Plaintiffs’ payment of such sums conferred a direct benefit upon Defendant and
81. Defendant’s acceptance of such benefit was at the expense of Plaintiffs who were
82. Defendant has failed to provide plaintiffs with an on-campus academic experience
for the Spring or Summer 2020 Arch semesters or to provide the related on-campus services.
83. It would be against equity and good conscience to permit Defendant to retain the
full amount of the tuition and fees paid to it by Plaintiffs for an on-campus experience and related
Defendant has been unjustly enriched and Plaintiffs are entitled to the disgorgement of such sums
in an amount to be determined upon the trial of this action and such other and further relief as this
85. In the alternative to the claims alleged above, Plaintiffs have no other adequate
remedy at law.
16
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D. Awarding compensatory and special damages, together with pre and post judgment
E. Granting declaratory relief adjudicating the parties’ legal rights and obligations;
Plaintiffs to Defendant for tuition and fees for the Spring 2020 semester and
Summer 2020 Arch semester or, in the alternative, the amount of such payments as
H. For the costs, disbursement, and reasonable attorneys’ fees of this action; and
I. For such other and further relief as this Court deems just and proper.
17
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initiatives including “Beyond the Internet: Digital Meets Reality” and “Infrastructural Resilience, Sustainability, and Stewardship.” In Undergraduate Education, we will target an under
Case 1:20-cv-00498-TJM-DJS
student population of 5,000 students. Broaden curricular offerings. Launch new Document 1-1 Filed
modalities of interactive 05/04/20
learning. Develop an ever Pagemore 2 of 28and transformative student exp
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through CLASS. Create new opportunities for research and international experiences. Launch a research-focused Honors Program. In Graduate Education, we will target a resident
student population of 2,500, with 1,600 Ph.D. students. Extend CLASS to graduate students. Grow interdisciplinary, research-based graduate programs. Focus graduate education and
on Global Challenges. Develop advanced professional programs that leverage interdisciplinary research. Create new technology-enabled learning environments. In Research, we will b
tenured and tenure-track faculty size to 500. Grow sponsored research expenditures to $250 million annually. Launch two new research umbrellas: “Beyond the Internet: Digital Meets
and “Infrastructural Resilience, Sustainability, and Stewardship.” Extend the Signature Thrusts to holistically address Global Challenges. Expand cross-sectorial research partnership
Communities of Rensselaer, we will strengthen our ethnic, gender, intellectual, and geographic diversity. Involve alumni/ae as partners in mutually beneficial ways to help advance the I
and to strengthen their connections to the Institute. Foster and support an innovation ecosystem to bring ideas from the classroom and the laboratory to the marketplace. Seek more d
collaborations at the local, regional, national, and global levels. In Enabling Change, we will mount a comprehensive fund-raising campaign, building upon the success of the $1.4 bi
naissance at Rensselaer Campaign. Target a goal of $150 million in annual philanthropic support. Maintain a robust infrastructure to support academic, research, and administrative a
Rensselaer will build upon its distinguishing strengths in interdisciplinary inquiry, interactive learning, and entrepreneurship to enhance national and international leadership in in
learning and teaching by providing an outstanding and distinctive education for resident undergraduates and graduate students, and for working professionals. Dramatically expand the
enterprise, including associated graduate education, by (i) creating new Institute-wide initiatives in signature research thrusts closely aligned with societal and global priorities; (ii) build
and enhancing existing core research strengths; (iii) strategically supporting additional critical priorities in areas that offer opportunities for research impact and leadership; and (iv)
new infrastructure that enables growth. Increase our focus on innovation and entrepreneurship across education, research, media and the arts, technology commercialization, and new
creation, to spur regional and national economic development, and to use science and technology for social advancement and environmental stewardship. Strengthen ethnic, gender,
tual, and geographic diversity among our students, faculty, and staff in order to draw upon the best talent available, and to prepare our students to work and lead in a global economy. R
our diverse communities on our campuses, among alumni/ae and friends, and in all of our activities locally, nationally, and globally. Redesign and invigorate enabling activities to foc
selaer people, administrative processes, information infrastructure, physical facilities, and financial resources on the realization of strategic goals. As Rensselaer moves toward its bicen
we will continue to build upon our unique strengths: interdisciplinary inquiry; interactive learning; innovation and entrepreneurship; CLASS; and leading-edge platforms. We will enhan
lectual diversity by developing unique degree programs in architecture; management; and humanities, arts, and social sciences, that incorporate the rich scientific and technological s
of the Institute, embracing as well the humanistic, artistic, and social dimensions of technology. Embed curricular and co-curricular activities designed to foster a culture of creativity, d
and innovation. Integrate outcomes assessment and evaluation into all education programs, ensuring timely and continuous improvement. We will target an undergraduate student bo
from which we recruit—nationally and internationally. Create new modalities of interactive learning by making use of structured online content and generating new tools to access, ag
and analyze unstructured data. Develop “online virtual environments” that extend the student experience in time and space, to create digitally connected classrooms, discussion gro
project settings with faculty and students at other universities, and with researchers, innovators, entrepreneurs, and policy-makers around the world. Use EMPAC, linked to other camp
forms, to develop and deploy highly developed immersive environments for digitally augmented learning. Expand the use of interactive assessment techniques to improve learning ou
We will create the opportunity for research or independent study for all undergraduate students. Establish an Honors Program to recognize and nurture distinctive achievement in r
Promote “Entrepreneurship Across the Curriculum” as a differentiator of a Rensselaer education. We will fully develop CLASS to anchor the developmental experience for all undergr
Use CLASS as a laboratory for pedagogical innovation. Integrate the Global Challenges as foundational elements of CLASS programming. Embrace diversity and inclusion as fundament
of CLASS. Develop appropriate metrics to measure outcomes of CLASS. We will target a resident graduate student population of 2,500, with 1,600 Ph.D. students. Strengthen the s
for admission to our graduate programs, drawing students from an expanded national and international base. Dramatically expand federally funded graduate training programs, partic
the intersection of basic and applied sciences, and engineering. Focus on comprehensive professional development for our graduate students. Align our professional degree programs
Global Challenges, linked to our signature research thrusts. Integrate the use of interactive assessment techniques to improve learning outcomes for all graduate education and training p
We will establish a Graduate Center to provide advocacy, support, and guidance for graduate students, and their families, throughout their tenure at Rensselaer. Develop concomitant p
ming and support for postdoctoral researchers, acknowledging that the postdoctoral position represents the culmination of formal graduate education. Significantly expand residential
options for graduate students and their families. Extend the precepts of CLASS to our working professional programs, including Rensselaer at Hartford. We will offer a complete studen
ence, highlighted by Clustered Learning, Advocacy, and Support for Students (CLASS). We will lead in pedagogical innovation, introducing new learning paradigms including the Mu
and Mixed Reality Classroom and Cyber-Enabled Discovery and Learning. We will extend our impact on humanity through forward-looking research initiatives including “Beyond the
Digital Meets Reality” and “Infrastructural Resilience, Sustainability, and Stewardship.” In Undergraduate Education, we will target an undergraduate student population of 5,000 s
Broaden curricular offerings. Launch new modalities of interactive learning. Develop an ever more engaging and transformative student experience, through CLASS. Create new oppo
for research and international experiences. Launch a research-focused Honors Program. In Graduate Education, we will target a resident graduate student population of 2,500, with 1,60
students. Extend CLASS to graduate students. Grow interdisciplinary, research-based graduate programs. Focus graduate education and research on Global Challenges. Develop advan
fessional programs that leverage interdisciplinary research. Create new technology-enabled learning environments. In Research, we will build the tenured and tenure-track faculty size
Grow sponsored research expenditures to $250 million annually. Launch two new research umbrellas: “Beyond the Internet: Digital Meets Reality” and “Infrastructural Resilience, Sus
ity, and Stewardship.” Extend the Signature Thrusts to holistically address Global Challenges. Expand cross-sectorial research partnerships. In the Communities of Rensselaer, we will s
en our ethnic, gender, intellectual, and geographic diversity. Involve alumni/ae as partners in mutually beneficial ways to help advance the Institute, and to strengthen their connectio
Institute. Foster and support an innovation ecosystem to bring ideas from the classroom and the laboratory to the marketplace. Seek more deliberate collaborations at the local, regional
al, and global levels. In Enabling Change, we will mount a comprehensive fund-raising campaign, building upon the success of the $1.4 billion Renaissance at Rensselaer Campaign.
goal of $150 million in annual philanthropic support. Maintain a robust infrastructure to support academic, research, and administrative activities. Rensselaer will build upon its distin
strengths in interdisciplinary inquiry, interactive learning, and entrepreneurship to enhance national and international leadership in innovative learning and teaching by providing an out
and distinctive education for resident undergraduates and graduate students, and for working professionals. Dramatically expand the research enterprise, including associated graduat
tion, by (i) creating new Institute-wide initiatives in signature research thrusts closely aligned with societal and global priorities; (ii) building upon and enhancing existing core research st
(iii) strategically supporting additional critical priorities in areas that offer opportunities for research impact and leadership; and (iv) building new infrastructure that enables growth.
our focus on innovation and entrepreneurship across education, research, media and the arts, technology commercialization, and new venture creation, to spur regional and national e
development, and to use science and technology for social advancement and environmental stewardship. Strengthen ethnic, gender, intellectual, and geographic diversity among our s
faculty, and staff in order to draw upon the best talent available, and to prepare our students to work and lead in a global economy. Revitalize our diverse communities on our campuses
alumni/ae and friends, and in all of our activities locally, nationally, and globally. Redesign and invigorate enabling activities to focus Rensselaer people, administrative processes, inf
infrastructure, physical facilities, and financial resources on the realization of strategic goals. As Rensselaer moves toward its bicentennial, we will continue to build upon our unique s
interdisciplinary inquiry; interactive learning; innovation and entrepreneurship; CLASS; and leading-edge platforms. We will enhance intellectual diversity by developing unique degree p
in architecture; management; and humanities, arts, and social sciences, that incorporate the rich scientific and technological strengths of the Institute, embracing as well the human
tistic, and social dimensions of technology. Embed curricular and co-curricular activities designed to foster a culture of creativity, discovery, and innovation. Integrate outcomes assessm
evaluation into all education programs, ensuring timely and continuous improvement. We will target an undergraduate student body size s from which we recruit—nationally and interna
Create new modalities of interactive learning by making use of structured online content and generating new tools to access, aggregate, and analyze unstructured data. Develop “onlin
environments” that extend the student experience in time and space, to create digitally connected classrooms, discussion groups, and project settings with faculty and students at othe
sities, and with researchers, innovators, entrepreneurs, and policy-makers around the world. Use EMPAC, linked to other campus platforms, to develop and deploy highly developed im
environments for digitally augmented learning. Expand the use of interactive assessment techniques to improve learning outcomes. We will create the opportunity for research or inde
study for all undergraduate students. Establish an Honors Program to recognize and nurture distinctive achievement in research. Promote “Entrepreneurship Across the Curriculum” as
entiator of a Rensselaer education. We will fully develop CLASS to anchor the developmental experience for all undergraduates. Use CLASS as a laboratory for pedagogical innovation. I
the Global Challenges as foundational elements of CLASS programming. Embrace diversity and inclusion as fundamental tenets of CLASS. Develop appropriate metrics to measure o
of CLASS. We will target a resident graduate student population of 2,500, with 1,600 Ph.D. students. Strengthen the standards for admission to our graduate programs, drawing stude
an expanded national and international base. Dramatically expand federally funded graduate training programs, particularly at the intersection of basic and applied sciences, and eng
Focus on comprehensive professional development for our graduate students. Align our professional degree programs with the Global Challenges, linked to our signature research thrus
grate the use of interactive assessment techniques to improve learning outcomes for all graduate education and training programs. We will establish a Graduate Center to provide a
support, and guidance for graduate students, and their families, throughout their tenure at Rensselaer. Develop concomitant programming and support for postdoctoral researchers,
edging that the postdoctoral position represents the culmination of formal graduate education. Significantly expand residential housing options for graduate students and their families
the precepts of CLASS to our working professional programs, including Rensselaer at Hartford. We will offer a complete student experience, highlighted by Clustered Learning, Advoc
Case 1:20-cv-00498-TJM-DJS Document 1-1 Filed 05/04/20 Page 3 of 28
We began our journey of transformation where necessity demanded. We have made major
investments in our people, programs, platforms, and partnerships; and, together, we have
brought about a true Renaissance at Rensselaer. These investments have enabled us to transform
Rensselaer into a top-tier technological research university with global reach and global impact.
That transformation serves as a solid foundation on which we will build even greater achievements
in the future.
Our journey of transformation continues, under The Rensselaer Plan 2024. In the same spirit as
its precursor, the revised Plan is evergreen, prepared to grow and evolve, as the Institute grows
and evolves. In advancing The Rensselaer Plan 2024, we are moving from transforming Rensselaer
to Rensselaer being transformative—transformative in our students’ lives; transformative in our
innovative pedagogy, nationally and internationally; transformative in the global impact of our
research.
TA B L E O F C O N T E N T S
e xec ut i ve s um m a ry 4
1 THE GOAL 6
2 FU NDAM ENTALS 8
2.1 Rensselaer Today 8
2.2 Accomplishments Under The Rensselaer Plan, 2000-2012 8
2.3 Unique Strengths 11
2.4 Opportunity and Global Challenges 11
5 R ESEAR CH 16
5.1 Growth of Signature Thrusts 16
5.2 Addressing Global Challenges 18
5.3 Intellectual Property, Technology Commercialization,
and Entrepreneurship 19
6 THE COMMU NI TI ES OF R EN S S E L A E R 20
6.1 The Diverse and Inclusive University Community 20
6.2 Alumni and Alumnae 20
6.3 Neighborhood, City, and Region 21
6.4 National and International Reach 21
7 ENABLI NG CHANGE 22
7.1 Administrative Process Re-engineering 22
7.2 Information and Cyber-Infrastructure 22
7.3 Physical Facilities 22
7.4 Advancing the Institute 23
7.5 Managing Financial Resources 23
7.6 Expanding the Resource Base 23
The goal of The Rensselaer Plan 2024 is • Education and research are inextricably linked
the rensselaer plan 2024
To realize this vision, a multifront, focused, Launch two new research umbrellas:
5
and engaged community effort will be required
Beyond the Internet: Digital Meets Reality
7
educational and research platforms to create and stewardship.
2000-2012
We will achieve our goal by embracing The Rensselaer Plan brought an examination of the
the rensselaer plan 2024
our fundamental values, identifying the intellectual core in key disciplines and a restructur-
key strengths on which we will build, ing of undergraduate and graduate offerings. To
and integrating our planning and action. advance The Plan, we have focused on the develop-
ment of people, programs, platforms, and partner-
2.1 Rensselaer Today ships. In the process, we have brought compre-
Building on its storied legacy, under The hensive change to every aspect of the Institute.
Rensselaer Plan the Institute has transformed
itself into a fully realized university that provides People: The Faculty
undergraduate and graduate education of undis- An exceptionally gifted professoriate—the very
puted intellectual rigor, with research impact and heart of educational excellence, and academic and
promise that extend to every continent. scientific rigor—is drawn to Rensselaer by bright
and motivated students, outstanding colleagues,
The Schools of Architecture; Engineering; supportive staff, advanced research facilities, and
Humanities, Arts, and Social Sciences; The Lally a culture that celebrates interdisciplinary inquiry.
School of Management and Technology; and We have established 34 new named chairs,
Science educate approximately 7,000 students— including 24 Constellation Professors. Over the
enrolling 5,300 undergraduates and approximate- course of The Rensselaer Plan, 275 faculty mem-
ly 1,250 graduate students in full-time programs bers have been hired, including outstanding early
on the Troy campus. Rensselaer at Hartford offers career people, helping to revitalize the faculty.
graduate programs for approximately 500 work- Over the decade, the National Science Foundation
ing professionals in engineering, business, and has honored 53 of our early career faculty mem-
the management of science and technology. bers with its prestigious Career Award.
During the life of The Rensselaer Plan, annual Rensselaer faculty members are deeply engaged
research funding has tripled, to $100 million. in discovery, knowledge creation, technological
The Institute is a leader in interdisciplinary and business innovation, and creative design.
research, and has made strategic investments Faculty members, well known for their forward-
in important new and existing research arenas. looking research and scholarship, welcome and
Rensselaer has attracted outstanding faculty encourage students as partners.
whose research programs represent a wide array
of fields including nanoelectronics; information Today, Rensselaer is home to 421 full-time faculty,
technology and Web science; computational sci- including 343 tenured and tenure-track faculty.
ence and engineering; business analytics; nano- As Rensselaer continues to build its faculty ranks,
technology and advanced materials; biotechnol- it has aggressively pursued greater representa-
ogy and the life sciences; environmental studies; tion of women and underrepresented minorities.
lighting and acoustics; and media, arts, science, We have developed systemic, university-wide
and technology. Our research programs are mak- approaches to advance and diversify faculty in
ing an impact on the problems facing society. academic engineering and science careers. The
They are leading to pivotal academic advances, percentage of women faculty has risen from 15
often with applications across multiple percent to 21 percent, and underrepresented
disciplines. minority faculty from 4 percent to 7 percent.
There is more to do.
New curricula and programs have enriched the
academic offerings at the Institute. Rensselaer People: The Students
has extended its distinction in interactive learn- Undergraduate admissions applications have
ing and the application of information and digital grown dramatically, with a threefold increase
technologies to education. compared to 12 years ago. Applications for full-
Case 1:20-cv-00498-TJM-DJS Document 1-1 Filed 05/04/20 Page 11 of 28
time graduate study have reached their highest Computational Science and Engineering;
9
levels ever. We have raised undergraduate and Media, Arts, Science, and Technology; Energy,
Albany Medical College. Several new Ph.D. pro- Programs: The Student Experience
10
grams have been initiated in Cognitive Science, Driven by The Rensselaer Plan, we have revitalized
Biochemistry/Biophysics, Architectural Sciences, the student experience through the creation of a
the rensselaer plan 2024
Course work and extracurricular/co-curricular The First-Year Experience (FYE) has transformed
opportunities are more deliberately global in the transition of new students into Rensselaer.
outlook, intellectually rigorous and sophisticated, We have fostered a greater sense of community
and socially nuanced, creating an environment within the residence halls and off-campus living
that promotes powerful, mind-opening new groups, enhanced support and counseling ser-
experiences, which foster intellectual agility and vices, and streamlined student-focused adminis-
greater multicultural understanding. trative processes.
Education in entrepreneurship is thriving across Indeed, the success of the First-Year Experience,
all schools and programs. We have created or and other initiatives, has given birth to a new
enhanced the entrepreneurial content of more living/learning paradigm: Clustered Learning,
than 100 courses across all five schools. We have Advocacy, and Support for Students (CLASS).
forged new curriculum tools, launched competi-
tions, and generated flourishing undergraduate We have expanded cultural offerings by broaden-
entrepreneurship research opportunities. ing our program of lectures, forums, music, and
the arts, by bringing programs into the residence
Our faculty, students, and staff actively embrace a halls, and by identifying opportunities for civic
culture of discovery, invention, innovation, and engagement.
partnership. They discover, design, build, serve,
and lead. We have re-energized our international educa-
tional and research outreach. We have launched
Because of the impact of our research, the talents REACH (Rensselaer Education Across Cultural
of our faculty and staff, and the capabilities of our Horizons), which sends undergraduate students
students, the Rensselaer degree is highly regard- abroad, and we have created exchange agree-
ed. Our graduates are actively sought by industry, ments in 12 countries with 22 institutions.
universities, and the public sector. They also The result for our students is a stronger affinity
create new wealth.
Stemming from our award-winning FYE CLASS embodies these core themes: Commons.” The Dean of the Off-Campus
program, we have developed a bold, personal, professional, leadership, and Experience extends CLASS precepts to
comprehensive, and holistic residential cultural development; communiversity; students who do not live in university
college model that provides unparalleled and community. CLASS provides a pro- housing. There are Class Deans who work
developmental education and support grammatic framework for strengthened with each undergraduate class, begin-
in every sphere of student life—from counseling, unique co-op experiences, ning in the sophomore year, to support
our revitalized residential settings to our academic skills building, cultural expo- academic, professional, and personal
leading-edge classrooms and laborato- sure, leadership opportunities, community growth as each class progresses through
ries. CLASS builds upon both residential building, and global engagement. its undergraduate years. Our substantive
and time-based clustering. It supports commitment to the physical well-being of
personal growth, social and academic Many of these activities originate within students is reflected in full-time athletic
excellence, and preparation for leader- the residential setting. The on-campus staff, the upgrade of women’s ice hockey
ship, by placing faculty and staff mentors residential clusters (“Commons”) have status to Division I, increased club and
and unique opportunities at the center of live-in Commons Deans who lead theme- intramural sports offerings, and sophis-
students’ lives. based programming in the residential ticated new facilities, including the East
setting. The clusters include the “Greek Campus Athletic Village (ECAV).
Case 1:20-cv-00498-TJM-DJS Document 1-1 Filed 05/04/20 Page 13 of 28
and connection to Rensselaer, a greater emphasis 20th centuries. They continue to do so in the 21st
11
on community and leadership, and a more holis- century.
Pedagogical Innovation
13
national honors for these enhancements of the student educational
this context, it is essential that our graduates have
experience. Our “next-generation studio” was an evolved version of
• Target a resident graduate student population of • Extend the precepts of CLASS to our working
2,500, with 1,600 Ph.D. students. professional programs, including Rensselaer at
Hartford.
• Strengthen the standards for admission to our
graduate programs, drawing students from an 4.3 A Distributed Rensselaer
expanded national and international base. We have witnessed the development of new tech-
nologically based pedagogical tools, the expansion
of new knowledge at unprecedented rates, and a
Research provides the intellectual grounding and training profound shift in the demographics and location
for the next generation of scholars and technological leaders. of potential students. The ability to host content
This requires a vibrant graduate student body and a strong on the Web, as well as to engage collaboratively
with students at remote locations, has opened
research-based resident graduate program that attracts new possibilities for delivering educational pro-
the most talented students. grams in different formats, in order to meet the
learning needs of working professionals.
• Dramatically expand federally funded graduate The Rensselaer Plan 2024 calls for a distributed
training programs, particularly at the intersec- Rensselaer that operates from its campuses in
tion of basic and applied sciences, and engineer- the Northeast, while reaching out to a broader
ing. audience of working professionals through
regional sites, technology-enabled distributed
• Focus on comprehensive professional develop- education, and international presence and part-
ment for our graduate students. nerships. We will:
• Align our professional degree programs with • Position Rensselaer as the educator of choice
the Global Challenges, linked to our signature in our areas of strategic focus through partner-
research thrusts. ships with major corporations, government
Case 1:20-cv-00498-TJM-DJS Document 1-1 Filed 05/04/20 Page 17 of 28
15
universities.
Rensselaer at Hartford
For more than 55 years, Rensselaer at Hartford
has offered master’s degree and certificate pro-
grams to working professionals in management,
engineering, and computer science. More than
22,000 alumni/ae have earned advanced degrees
at Hartford. Courses are offered on the main
Hartford campus and at satellite campuses and
corporate facilities. Instruction occurs in tradi-
tional classrooms and in a blended format.
We will:
• Grow the Hartford enrollment to 1,200 working
professionals in degree programs.
• Significantly broaden the base of corporate
clients served at Hartford.
• Link the Hartford educational offerings to the
core research strengths of the Institute.
Case 1:20-cv-00498-TJM-DJS Document 1-1 Filed 05/04/20 Page 18 of 28
Rensselaer over the past decade has Performing Arts Center; and the Center for
been the creation of a research portfolio Materials, Devices, and Integrated Systems,
which includes the Micro/Nano-Fabrication
of a size, significance, quality, and prom-
Facility and the Materials Characterization Core.
inence that positions us to impact
Global Challenges. Collectively, the Signature Thrusts, centers, and
platforms provide the basis for significant contri-
Over the past 12 years, Rensselaer has butions in the years ahead.
solidified its place among the important
As we enter the next phase of research at
technological universities of the 21st cen- Rensselaer, it is essential to link our strengths in
tury by investing in topnotch research- the five Signature Research Thrusts to the Global
ers, broad-based programs, sophisticated Challenges facing society.
research platforms, and strategic part- We now have a broad, collaborative and vibrant
nerships. Important new research has research community at Rensselaer, focused on
emerged from strategic investments in the growing interface of the basic sciences, social
the Institute-wide signature research sciences, and engineering. This provides the
basis for innovative solutions to today’s Global
thrusts of Biotechnology and the Life Challenges, including: mitigating disease; provid-
Sciences; Computational Science and ing clean food and water; developing new sources
Engineering; Media, Arts, Science, and of clean and renewable energy; and establishing a
Technology; Energy, Environment, and sustainable and resilient national and internation-
al infrastructure. We are inventing new routes to
Smart Systems; and Nanotechnology and advanced manufacturing that lead to new prod-
Advanced Materials. ucts and processes. We are developing new mate-
rials for advanced computing, energy storage, and
Rensselaer has developed a broad and unique medicine. We are pioneering new technologies
network of outstanding research centers such to manage the explosion of data from new com-
as: the NSF Nanoscale Science and Engineering munication networks and control systems. We
Center; the NSF Smart Lighting Engineering are working to understand human cognition in
Research Center; the Lighting Research Center; communication and culture and to navigate the
the Center for Modeling, Simulation, and complexity of global markets.
Imaging in Medicine; the Scientific Computation
Research Center; the U.S. Army Research We will address these challenges and opportuni-
Laboratory—Social Cognitive Networks Academic ties to have even greater levels of impact in the
Research Center; the Center for Cognition, years ahead.
Communication, and Culture; the Bioengineered
Heparin Consortium; the Center for Architecture 5.1 Growth of Signature Thrusts
Science and Ecology; the New York Center Our five Signature Thrusts and core research
for Astrobiology; the Center for Automation strengths will serve as the foundation for contin-
Technologies and Systems; and the Center for ued growth and impact. Therefore, we will:
Future Energy Systems.
• Grow research funding to $250 million in
Our research efforts are undergirded by an inte- annual research expenditures.
grated network of major research platforms, • Strengthen basic research endeavors across
including: the Center for Biotechnology and the Institute.
Case 1:20-cv-00498-TJM-DJS Document 1-1 Filed 05/04/20 Page 19 of 28
17
Energy, water, food
n n n n
Global markets
n n
Advanced manufacturing
n n n n n
Data/networks/HPC
n n n
In Energy, Environment, and Smart manufacturing new functional hybrid Enabled by the capabilities of the CCNI,
Systems, we explore renewable technolo- materials, and the hierarchical systems Rensselaer has developed important
gies, energy efficiency, and the under- and products based upon them. In programs in Computational Science and
standing of global environmental change Biotechnology and the Life Sciences, we Engineering focused on high perfor-
to preserve the bio-diversity of the planet. are creating new routes to drug discovery mance computing, big data, and data
Our excellence in Nanotechnology and and development, and understanding analytics, which supports research and
Advanced Materials builds from the fun- the fundamental mechanisms of dis- innovation across a broad front. Research
damental understanding—experimental, ease, from Alzheimer’s and diabetes to in Media, Arts, Science, and Technology
theoretical, and computational—of the cancer. The intersection of life sciences facilitates new approaches to networking,
underlying atomic and molecular proper- with the physical sciences and engineer- advanced visualization, sensor design,
ties of a wide range of nanostructured ing fosters advances in areas such as haptics, and multiscale modeling and
materials. We now are developing robust, biomanufacturing, antimicrobial surfaces simulation, which are supported by the
affordable, and sustainable methods for and coatings, and regenerative medicine. core capabilities of EMPAC.
Case 1:20-cv-00498-TJM-DJS Document 1-1 Filed 05/04/20 Page 20 of 28
• Promote applied research that enables rapid 5.2 Addressing Global Challenges
translation of innovative solutions to key Global In building on our achievements in Signature
Challenges. Thrust areas, in order to address one or more
Global Challenges, we choose to address topics
• Continue to recruit and support leading faculty
that are scientifically rich and challenging—from
in identified priority areas, with a goal of build-
data analytics, healthcare technologies, sustain-
ing the tenured and tenure-track faculty size to
able infrastructure, and advanced manufacturing
500.
to cyber-infrastructure/security, big data, and
• Continue to invest in exceptional research infra- environmental change. Therefore, we will:
structure, including important core facilities
within flexible research platforms. • Strengthen existing and develop new Signature
Thrusts that link to Global Challenge areas.
• Establish partnerships through multiple sectors
to expand the research reach and impact of the • Create new “constellations” of exceptional facul-
Institute. ty, staff, and students in Signature Thrust areas
linked to Global Challenges.
• Position Rensselaer to shape the national and
international scientific, technological, economic, • Select and nurture new areas of focus that
and societal agenda. match our core strengths and physical infra-
structure.
• Measure key outcomes related to impact and
leadership, including faculty recognition and • Expand mechanisms for extramural research
sponsored research growth. and activities with the federal government,
industry, and non-government organizations.
BEYOND THE INTERNET: culture, and politics. Such research rests Data Analytics. Data-driven innovation is
DIGITAL MEETS REALITY on interdisciplinary breakthroughs link- critical to addressing healthcare econom-
ing computer science, cognitive science, ics, quality of care, and therapeutics;
The ubiquitous availability of data and
Web science, and the life and physical translational medicine; advanced manu-
information, coupled with massive digital
sciences. facturing; transformative materials; smart
interconnectivity, has enabled new means
logistics; discovery and innovation; and
of discovery, sharing of information, and
CyberInfrastructure, Cyber-Security, and workforce productivity and effectiveness.
enhanced analysis and data validation.
Technology-Assisted Decision Making. Exploiting semantic technologies to access
Information extracted from massive data
A robust cyberinfrastructure depends on and use unstructured data from disparate
sets will elucidate relationships from
digital data management, stewardship, sources will yield unique insights across a
seemingly disparate contexts, while com-
analysis, and preservation in industry and broad spectrum.
putationally based modeling and simula-
tion will enhance real-time decision mak- academia. Fundamental to this is cyber-
security, which requires breakthroughs INFRASTRUCTURAL RESILIENCE,
ing in research, education, business and
finance, healthcare, and public policy. in algorithmic and system development SUSTAINABILITY, AND STEWARDSHIP
and validation, and in network architec-
Addressing water, food, and energy
ture design. Research rooted in synthetic
Engineering Natural and Man-made security, public health, climate change,
immersive worlds and digitally enriched
Networks. Advances in computation, data and the built environment is critical to a
environments can enhance technology-
aggregation and data analytics, and artifi- sustainable future. This requires a holistic
assisted decision-making under normal
cial intelligence provide the new underpin- approach to improve resilience, sustain-
and emergency conditions.
nings of social, cognitive, and computer ability, quality of life, and the stewardship
networks that are enabling the study of of our natural and man-made resources.
the impact of such networks on society,
Case 1:20-cv-00498-TJM-DJS Document 1-1 Filed 05/04/20 Page 21 of 28
Emerging Ventures
Ecosystem
The original Rensselaer
incubator has been trans-
5.3 Intellectual Property, Technology • Increase awareness of intellectual prop- formed into the Emerging
19
Commercialization, and Entrepreneurship erty, preserving its value in agreements Ventures Ecosystem
The Rensselaer Plan 2024 articulates a strategic 7.2 Information and Cyber-Infrastructure
vision for the Institute, and delineates the means An integrated information environment is essen-
to achieve it. An “evergreen” plan, designed to be tial to teaching, learning, and research. We must
updated on a regular basis, The Plan guides our enhance our first-rate information culture and
decisions, and provides the framework for school powerful information infrastructure by valuing
and divisional performance plans that serve as information and cyber-literacy at every level and
the basis for each year’s overall operating plan implementing new methods for scholarly com-
and budget. Performance plans define means and munication and electronic interactions. We will:
metrics, and when prioritized, create the case for
major new resources. The means and metrics • Provide an integrated portfolio of education,
must link to key outcomes in each area that we access, and support technologies, policies, and
pursue. services for teaching, learning, and research.
• Develop a sophisticated business analytics
We will focus new resources—be they substantial
culture to improve distributed decision support
new assets or savings from effective use of exist-
throughout the Institute.
ing resources—to areas of the highest priority.
Under The Rensselaer Plan 2024, discretionary, • Create new delivery models for improved user
incentive, and new resources will be directed experience and increased accessibility, connec-
toward identified priorities in research, pedagogy, tivity, reliability, and operational efficiency.
and other core activities.
• Maintain a secure cyber-infrastructure that
provides for appropriate levels of access,
7.1 Administrative Process Re-engineering
security, and privacy.
The Plan requires that we achieve high perfor-
mance levels in key administrative processes in • Provide intuitive multimedia access to scholarly
increasingly efficient ways. We will: materials for research and education purposes.
• Partner with other universities, companies, and
• Focus all portfolios on the goals and strategies
public agencies to augment the intellectual and
of The Rensselaer Plan 2024.
capital resources of the Institute.
Case 1:20-cv-00498-TJM-DJS Document 1-1 Filed 05/04/20 Page 25 of 28
LEADERSHIP IN THE
24
21st CENTURY
the rensselaer plan 2024
BNYNDC-5108521 DJS
$400.00 TJM
1:20-CV-498