Full opinion text
MEMORANDUM AND ORDER ANITA B. BRODY, District Judge. Plaintiffs Nick Embrico, Richard E. Thomas, Frank Vitucci, and Roy Williams are all former non-union managerial employees of the Fairless Works plant owned by the defendant United States Steel Corporation (“U.S.Steel”). They all retired under the defendant’s “Voluntary Early Retirement Program” (“VERP”) in the fall of 2001. The plaintiffs bring this action alleging that the manner in which the defendant implemented its VERP violated the Age Discrimination in Employment Act (ADEA) of 1967, 29 U.S.C. §§ 621 et seq. (2005), the Pennsylvania Human Relations Act (PHRA), Pa. Stat. Ann. Tit. 43 §§ 951 et seq. (2005), and the Employee Retirement Income Security Act (ERISA), 29 U.S.C. §§ 1001 et seq. (2005). Additionally, Plaintiffs Thomas and Williams allege that U.S. Steel discriminated against them on the basis of race, in violation of Title VII of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. § 2000e-5 (2005), and the PHRA. Plaintiff Vitucci also alleges that U.S. Steel violated the retaliation provision of the ADEA when it allegedly failed to secure him a position at Fairless Works as an independent contractor after he retired. Pursuant to 28 U.S.C. §§ 1331 and 1367, subject-matter jurisdiction is proper due to the presence of a federal question. Before me is the defendant U.S. Steel’s motion for summary judgment. For the reasons that follow, I will grant the motion as to all counts. I. Background All four plaintiffs are former employees of Fairless Works, a steel manufacturing plant owned and managed by U.S. Steel and located in Bucks County, Pennsylvania. (Def.’s Reply at 1.) When it opened in 1952, Fairless Works was a steel mill with several operations. (Id.) Over the years that followed, Fairless Works underwent a number of restructurings. Finally, in 1991, U.S. Steel shut down a majority of the plant, reducing Fairless Works’s operations to a “Tin Line” or “tin operation” and a “Galvanized Line” or “galvanized operation” (sometimes referred to as “the sheet operation” by the defendant). (Id.) At some point during the 1990s, U.S. Steel began to contemplate closing the Tin Line at Fairless Works. (Pl.’s Second Amend. Resp. to Def.’s Mot. for Summ. J. at 11.) On August 2, 2001, at the request of Fred Harnack, General Manager of the Mon Valley Works facility, and David Lohr, Vice President of Operations, Fair-less Works Operating Manager Dennis Jones (“Jones”) prepared and submitted two planning documents in anticipation of a possible Tin Line closure at Fairless Works. (Id. at 8-9; Pl.’s Ex. E.) Jones’s first document was a memorandum entitled “Fairless Galvanize Manning” (“the Manning Proposal”). Jones characterized it as a “restructuring evaluation and proposal to minimally man the Fair-less Galvanize Operation as a stand-alone profitable entity ...” (Pl.’s Second Amend. Resp. at 8; PL’s Ex. E.) The Manning Proposal contained a projected list of Operating and Administration positions that would be needed after the closure. (See Jones Dep., PL’s Ex. F, “Jones Ex. 3.”) Jones described his second document, “the Roster,” as a “preliminary management and administrative roster, including those required to run the facility as well as those available for other assignments.” (Pl.’s Second Amend. Resp. at 8-9; PL’s Ex. E.) The Roster contains two lists. (Jones Dep., PL’s Ex. F, “Jones Ex. 4.”) The first list, entitled “Galvanize Only-Management Staff,” lists eighteen of the administrative positions named in the Manning Proposal, with the names of one or two Fairless Works managers next to each position and generally no comments or notations next to their names. The second list, entitled “Others Not Included in Above,” lists twenty-eight names, including all four plaintiffs. Under a column entitled “Comments,” notations such as “Pension,” “Transferable,” “Realty” and “No Plan” appear next to the names on the second list. The right-most column, entitled “Rating/Other,” lists a performance rating next to thirteen of the twenty-eight listed employees, including the plaintiffs. In explaining the development of the Roster’s “Galvanized Only Management Staff’ list, Jones testified that it was a list of the employees whom he considered the most qualified to fill positions on the Galvanized-only Line. (Jones Dep., PL’s Ex. F at 103, Ins. 16-21; id. at 192, Ins. 2-5.) The plaintiffs contend that this list represented those employees who were pre-selected for retention, in advance of U.S. Steel’s offer of the VERP. Jones contended that his primary focus was the “technical background” of the employees, such as whether they had “mechanical engineering degrees, electrical engineering degrees, or [had] worked in maintenance.” (Id.) He justified this focus by claiming that the shutdown of the Tin Line required “individuals that are technical to help address issues and train ... operators to do the maintenance work.” (Id. at 60, Ins. 12-24.) He based this opinion on his knowledge of the success of the “Protech facility,” a facility co-owned by U.S. Steel that had hired “technical people” for all its operating positions. (Id. at 124, Ins. 3-19.) Jones admitted, however, that he did not do a formal check of personnel files before composing the Roster. (Id. at 188, Ins. 8-14.) Instead, he based his information on his dealings with the employees over the years and his knowledge of their educational backgrounds and experience. (Id.) In explaining his “Pension” notations on the Roster’s “Others Not Included Above” list, Jones claimed that the “pension” notation represented his “best guess” as to what those employees would be likely to do in the event of a shutdown (i.e., retire). (Jones Dep., PL’s Ex. F at 73, In. 6-74, In. 16.) Jones admitted that he did not speak to any of these employees about their retirement intentions before composing the Roster. (Id. at 73 at Ins. 9-21.) Rather, Jones claimed that he gathered his impressions from conversations and discussions that “everybody” had engaged in during prior Fairless Works restructurings. (Id. at 76, In. 23-77, In. 5.) According to Robert Kennedy (“Kennedy”), then-Manager of Employee Relations, in the face of a shutdown it was standard practice for U.S. Steel management to “look at ... what was required to run the operation after the fact and what positions would be needed.” (Kennedy Dep., PL’s Ex. H at 22, Ins. 1-5.) In his testimony on U.S. Steel’s procedures before a shutdown, Randall Lee Wynkoop (“Wynkoop”), General Manager of Benefit Administration and Vice President of Administration for U.S. Steel and the Carnegie Pension Fund, said that “[i]t wouldn’t surprise” him that Fairless Works management would “try to figure out how many total bod[ies]” would be needed after the closure. (Wynkoop Dep., Pl.’s Ex. A at 35, Ins. 12-14.) According to Wynkoop, it was standard practice for U.S. Steel when contemplating a voluntary reduction in force to “put together schedules and totals to say how many people are immediately pension eligible versus how may people are not immediately pension eligible” (id. at 36, Ins. 11-18), so that the management could “apply a reasonable guess as to what percentage of these immediate retirements are going to take the program” and make an informed cost estimate (id. at 37, Ins. 7-9). However, Wyn-koop also testified that he “never predicted” which specific individuals would be likely to retire and that he had “never seen [that] done” by U.S. Steel before. (Id. at 29, In. 15; id. at 35, Ins. 15-18.) Also commenting on the company’s procedures in the face of a shutdown, Vice President of Employee Relations James Garraux (“Garraux”) testified that it would be “irrelevant” to consider performance evaluations in planning a voluntary reduction in force, because any employee could choose to retire, regardless of his or her rating. (Garraux Dep., PL’s Ex. D at 36, Ins. 13-23.) At some point in 2001, U.S. Steel began to contemplate offering a Voluntary Early Retirement Program (“VERP”) to the employees at Fairless Works. (Garraux Dep., PL’s Ex. D at 70, Ins. 1-19.) This offer was to be in conjunction with a VERP it was planning to offer to the personnel at its Pittsburgh Headquarters. (Id.) Garraux testified that the leadership at U.S. Steel “didn’t want to do less for [Fairless Works] than we were doing for the Pittsburgh people.” (Id. at 70, Ins. 10-12.) On August 14, 2001, U.S. Steel publicly announced its intention to close the Tin Line at Fairless Works. There was much “uncertainty and concern” among the workers about whether U.S. Steel would be conducting involuntary layoffs due to the impending closure. (Kennedy Dep., PL’s Ex. H at 101, In. 16-102, In. 12.) In mid-October 2001, U.S. Steel distributed written materials announcing its offer of the VERP to the sixty-four eligible employees at Fairless Works. (PL’s Second Amend. Resp. at 16.) U.S. Steel also provided individual estimates to each employee of his or her pension benefits with and without the VERP enhancements. Most employees at Fairless Works, even younger employees, were eligible for enhanced benefits under the VERP. (Id. at 2-3; PL’s Ex. B.) Employees were given until November 30, 2001 to elect to participate in the VERP (“the VERP election period”). In the written materials distributed by U.S. Steel, the company informed its employees that “in the event that sufficient reductions are not attained from this Program, layoffs may result.” (PL’s Ex. B.) On November 8, 2001, U.S. Steel held two information sessions for employees about the VERP. (PL’s Second Amend. Resp. at 17.) At these meetings U.S. Steel did not disclose how many jobs would remain at the plant after the shutdown, nor what criteria would be used should layoffs be required. (Id.) During the VERP election period, Fair-less Works supervisors Jones and Kennedy met privately with at least three managers at Fairless Works, who were all Caucasian and younger than the plaintiffs (see Def.’s Resp. to Pl.’s Interrogs., Pl.’s Ex. N, “Ex. D”). At least one of these managers was told that he would be retained after the closure. None of these managers accepted the VERP. (See Def.’s Resp. to Pl.’s Interrogs., PL’s Ex. N, “Ex. D.”) By the end of the VERP election period, forty-three of the sixty-four eligible employees elected to accept the VERP, including the plaintiffs and eight of the nineteen individuals allegedly pre-selected for retention on Jones’s Roster. (See Def.’s Resp. to PL’s Interrogs., PL’s Ex. N, “Ex. D.”) Five employees who appeared on the bottom list of Jones’s Roster (the “Others Not Included Above” list) refused the VERP; two of those were eventually retained. (Jones Dep., PL’s Ex. F, “Jones Ex. 1.”) Of the twenty-one employees who refused the VERP, sixteen were eventually retained at the Galvanized Line after the closure. (Id.) At least three of the sixteen who were retained had met privately with Jones during the VERP election period; at least one of the sixteen had been privately reassured by Kennedy during the VERP election period. (See supra note 6.) On or about June 27, 2002, Vitucci and Embrico filed complaints of age discrimination against U.S. Steel with the Equal Employment Opportunity Commission (EEOC). (CompLW 34-35.) On the same date, Williams and Thomas filed complaints of age and race discrimination with the EEOC. (Id.) At the plaintiffs’ request, the EEOC cross-filed charges with the Pennsylvania Human Rights Commission (PHRC). (Id. ¶ 36.) On or about July 7, 2003, the EEOC sent Embrico and Vitucci letters indicating that the EEOC had closed its investigation of their charges under the ADEA. (Id. ¶ 38.) On or about July 9, 2003, the EEOC sent Thomas and Williams Notices of Right to Sue. (Id. ¶ 37.) A. Facts Relating to Nick Embrico In 2001, Embrico was fifty-seven years old. (Embrico Dep., PL’s Ex. R, “Ex. 2.”) He was hired at Fairless Works in May 1966. (ComplY 9.) By 2001, Embrico held the non-union position of shop services manager. (Embrico Dep., PL’s Ex. R. at 17, In. 16.) During the approximately thirty-five years that Embrico worked at Fair-less Works, he had been assigned to “new areas over the years with no training,” which led him to believe that he “could have worked anything in the Galvanized Line” even though it was a new area for him. (Id. at 61, In. 20-62, In. 12.) Kennedy testified that Embrico would “conceivably” have been qualified for a position on the Galvanized Line. (Kennedy Dep., PL’s Ex. H at 87, Ins. 12-16.) Jones testified that he would have considered Embrico as a candidate for retention “[biased on my interface with him and his ... performance,” although Jones felt that “there were other candidates that had [a] stronger background in [day-to-day maintenance functions].” (Jones Dep., PL’s Ex. F at 185, In. 20-187, In. 7.) Embrico has “basically a high school education.” (Embrico Dep., PL’s Ex. R at 6, In. 24-7, In. 4.) On Jones’s Roster, Embrico’s name was listed on the “Others Not Included Above” list, with the comment “Pension” and a performance rating of “5A” (out of a possible high of eight) next to his name. (Jones Dep., PL’s Ex. F, “Jones Ex. 1.”) At U.S. Steel, a rating of five indicates satisfactory performance and is considered to be an average acceptable score. During the VERP election period, Em-brico spoke with Division Manager Frank Coon (“Coon”) about the upcoming shutdown, and Coon informed him that U.S. Steel “hoped ... no later than the end of October to contract out all the services that [Embrico’s] departments provided ... [a]nd when that happened, [Coon] was going to have [Embrico] lay off all the employees [in his departments].” (Embrico Dep., Pl.’s Ex. R at 39, In. 12-40, In. 23.) Jones, Kennedy and Department Manager Preston Henderson (“Henderson”) expressly told Embrico that they did not know whether he would be retained at Fairless Works. {Id. at 42, In. 15-43, In. 7.) Nonetheless, Embrico surmised from his conversation with Coon that his current position would not exist after the closure. {Id. at 40, Ins. 8-16.) Embrico further concluded that he would not be transferred because “[i]n the past, when I was eligible for VERPs before, usually the division manager would call you up into the office and ask you if you had a preference ... of where you would like to transfer to. That didn’t happen this time.” {Id. at 49, Ins. 17-22.) Embrico was given a document that estimated that he would receive $564,212 with VERP enhancements, as compared to $434,670 without. {Id., “Ex. 2.”) He decided to participate in the VERP because he felt that “[U.S. Steel] forced me to retire.... They didn’t give me any options.” {Id. at 67, Ins. 9-11.) Embrico accepted the VERP on November 2, 2001, at age fifty-seven. (PL’s Second Amend. Resp. at 21; Embrico Dep., PL’s Ex. R, “Ex. 2.”) All sixteen of the managerial employees who were retained after the closure were at least five years younger than Embrico, ranging from twenty-five to fifty-one years of age. (Defi’s Resp. to PL’s Interrogs., PL’s Ex. N, “Ex. D.”) B. Facts Relating to Roy Williams Plaintiff Roy Williams is African American and was fifty-seven years old in 2001. (Williams Dep., PL’s Ex. S, “Ex. 1.”) He was hired at Fairless Works in January 1974. (ComplJ 12.) By 2001, Williams held the non-union position of transportation manager. (Williams Dep., PL’s Ex. S at 9, Ins. 16-17.) On the Roster prepared by Jones, Williams’s name was listed on the “Others Not Included Above” list, with the comment “Transferable” and a rating of “6A” next to his name. (Jones Dep., PL’s Ex. F, “Jones Ex. 1.”) At U.S. Steel, a rating of six indicates “above average” performance and is considered to be an “average acceptable score.” {See supra note 9.) Williams describes his educational attainment as “the rough equivalent of about two years” of college, gained through liberal arts classes he took while in the army in the late 1960s to early 1970s. (Williams Dep., PL’s Ex. S at 7, Ins. 2-21.) Williams believed that he “could have continued with the position that [he] had” after the closure, because U.S. Steel “could have expanded” that position at the Galvanized Line. (Williams Dep., PL’s Ex. S at 55, In. 24-56, In. 7.) Williams had been asked in 1997 if he wanted to work on the Galvanized Line, an offer that he had refused. {Id. at 56, Ins. 8-14.) Kennedy testified, once again with the caveat that he had not “lookfed] at ... all of the records,” that Williams could have been qualified to fill a position on the Galvanized Line. (Kennedy Dep., PL’s Ex. H at 87, Ins. 8-10.) Jones testified that he would have considered Williams for retention if the other candidates he had pre-selected had not been available. (Jones Dep-., Pl.’s Ex. F at 185, Ins. 8-15.) Williams approached two managers about his future job prospects during the VERP election period, Coon and Jones. Both declined to give him any advice “one way or the other” (Williams Dep., PL’s Ex. S at 38-43), which Williams took to mean that he would not be retained (id. at 37, Ins. 8-18). No one advised him to accept the VERP. (Id. at 43, Ins. 16-20.) Although Williams had no first-hand knowledge of anyone receiving private reassurances, Williams testified that Raya Szelest (“Szelest”), then-Personnel Analyst, told him that Greg Luczny and other managers had been told that their jobs were safe. (Id. at 49, In. 22-51, In. 2.) Williams decided that he would not be retained, because “no one told [me] that [I was] going to [be] retainfed] and [my] seniority meant nothing and they weren’t going to transfer [me].” (Id. at 45, Ins. 2-6.) Williams was given a document estimating that he would receive $511,203 in pension benefits with the VERP, compared to $288,899 without. (Id., “Ex. 1.”) Williams accepted the VERP on November 15, 2001, at age fifty-seven. (PL’s Second Amend. Resp. at 22; Williams Dep., PL’s Ex. S, “Ex. 1.”) Of the sixteen employees who were retained, all were Caucasian. (Def.’s Resp. to PL’s Inter-rogs., PL’s Ex. N, “Ex. D.”) All of these employees were at least five years younger (ranging from twenty-five to fifty-one years of age) than Williams. (Id.) C. Facts Relating to Frank Vitucci Plaintiff Frank Vitucci was fifty-four years old in 2001. (Vitucci Dep., PL’s Ex. U, “Ex. 1.”) He was hired at Fairless Works in August 1967. (Comply 11.) By 2001, Vitucci held the non-union position of facility maintenance manager. (Vitucci Dep., PL’s Ex. U at 18, Ins. 6-21.) On the “Roster” prepared by Jones, Vitucci’s name was listed under “Others Not Included Above,” with a comment, “Pension,” and a rating of “4A” next to his name. (Jones Dep., PL’s Ex. F, “Jones Ex. 1.”) At U.S. Steel, a rating of four indicates satisfactory performance and is considered to be an average acceptable score. (See supra note 9.) Vitucci holds an associate’s degree in business administration and was “in and out for maybe a year and a half’ of bachelor’s degree studies at Trenton State University in the late 1970s. (Vitucci Dep., PL’s Ex. U at 5, Ins. 4-24.) During his tenure at Fairless Works, Vitucci gained experience in “contracting out” and had “gotften] involved'in every aspect of every form of maintenance [and] production that there is.” (Vitucci Dep., PL’s Ex. U at 67, Ins. 12-17.) As a result, he believed he was “more qualified” than those who were retained at Fairless Works after the Tin Line closure. (Id. at 67, Ins. 10-11.) Kennedy testified that Vitucci would “conceivably” have been qualified for a position on the Galvanized Line. (Kennedy Dep., PL’s Ex. H at 87,' Ins. 12-16.) Jones testified that Vitucci’s “performance as far as controlling the budget was not satisfactory [and] his performance on directing employees to do things directly relating to [the] line was not satisfactory.” (Jones Dep., PL’s Ex. F at 182, Ins. 3-6.) Jones also claimed that Vitucci had mishandled a sexual harassment claim that he had been directed to manage in 2001. (Id. at 178-181.) During the VERP election period, Vituc-ci approached Kennedy, Coon and Jones to ask about his job situation, but they advised him that they did not know anything. (Vitucci Dep., PL’s Ex. U at 39, Ins. 12-18.) Neither they nor any other manager advised Vitucci to accept the VERP. (Id. at 59-60.) According to Vitucci, Coon told him that his department was going to be “eliminated” and “hinted ... in a roundabout way without saying it” that Vitucci’s position would no longer exist after the closure. (Id. at 38, Ins. 18-22.) Vitucci had no first- or second-hand knowledge of anyone receiving private reassurances pri- or to the VERP deadline, but had been told by Plaintiff Williams that Szelest had told him that others had received private assurances. (Id. at 33, In. 22-36, In. 15.) Vitucci was given a document that estimated that he would receive $569,905 in pension benefits with the VERP, compared to $418,337 without. (Id., “Ex. 2.”) Vitucci accepted the VERP on November 11, 2001, at the age of fifty-four. (PL’s Second Amend. Resp. at 21; Vitucci Dep., PL’s Ex. U, “Ex. 1.”) Of the sixteen employees who did not elect the VERP and were retained, fourteen were at least five years younger (ranging from twenty-five to forty-nine years of age) than Vitucci; two, who were both fifty-one, were close to Vitucci’s age. (Def.’s Resp. to PL’s Inter-rogs., PL’s Ex. N, “Ex. D.”) On or about October 26, 2002, a maintenance outage at Fairless Works was scheduled to occur. (PL’s Second Amend. Resp. at 28.) In the fall of 2002, approximately two months after Vitucci filed his EEOC complaint, Paul Denis (“Denis”), a mechanical maintenance manager at Fair-less Works, contacted Mike Murphy (“Murphy”), an employee of Joule, Inc., an outside contracting company, in order to obtain a project manager to assist Denis during the outage. (Denis Dep., PL’s Ex. X at 33, In. 23-34, In. 16.) Murphy contacted Vitucci about this potential job opportunity and Vitucci expressed interest in the position. (PL’s Second Amend. Resp. at 55.) Vitucci states that Murphy told him that Murphy had gotten his name from Denis. (PL’s Second Amend. Resp. at 29; see Vitucci Dep., PL’s Ex. U at 75, Ins. 7-13.) However, Denis denies this assertion, stating that Murphy was the one who suggested Vitucci, and that Denis indicated to Murphy that he was not interested in Vitucci. (Denis Dep., PL’s Ex. X at 34, Ins. 9-18.) According to Vitucci, Murphy told him that he would be meeting with Denis and would inform them of his intention to fill the position with Vitucci. (See Vitucci Dep., PL’s Ex. U at 76, Ins. 4-6 and 12-23.) In his deposition, Denis did not confirm this testimony and indicated that he did not recall the contents of this particular meeting. (Denis Dep., PL’s Ex. X at 67, Ins. 11-23.) Denis claimed that it was Joule, Inc. who made the decision to hire Robert Vander Decker (“Vander Decker”) instead of Vitucci. (Id. at 41, Ins. 1-6.) However, Denis admitted stating his preference to Joule, Inc. for Vander Decker over Vitucci for the independent contractor position. (Id.) According to Vitucci, on or about the following day, Murphy informed him that' his services would not be needed because U.S. Steel had changed the scope of the project. (Compl. ¶ 73; Pl.’s Second Amend. Resp. at 29.) Denis claimed that he was not aware during this period that Vitucci or any of the other plaintiffs had filed discrimination complaints relating to the VERP. (Denis Dep., Pl.’s Ex. X at 41, In. 22-42, In. 12.) Vitucci testified to his belief that senior managers Jones and Henderson had to have been aware of his EEOC filing, and that Denis would have had to get Joule, Inc.’s choice cleared by Jones and Henderson. (Vitucci Dep., PL’s Ex. U at 80, Ins. 5-7.) Denis admitted that Vander Decker, the individual that Joule, Inc. hired to fill the independent contractor position, had no previous experience in supervising “a half a million dollar outage” such as this one and had never worked at a steel mill before. (Denis Dep., PL’s Ex. X at 78, Ins. 16-23 and 35, Ins. 23-25.) However, Denis claimed that Vander Decker “looked like a perfect project manager” (id. at 34, In. 25-35, In. 1) because Vander Decker “said all the right things” and “knew how to do all the various Excel spreadsheets” (id. at 35, Ins. 2-4). Denis testified: “I didn’t believe [Vitucci] had the administrative background, he had a good working knowledge of people and jobs, but I don’t think he could do the Excel spreadsheets I needed done, I didn’t think he could do the time reports on the contractors that I needed to have done.” (Id. at 35, Ins. 14-20.) To Denis’s knowledge, Vitucci “was familiar with our trades” (id. at 79, In. 3), although he believed that Vitucci had “only operated with two of them ..., bricklayers and welders” (id. at 79, Ins. 4-5). Denis could not recall Plaintiff Vitucci having any experience in. “direct supervision over machinists and electrical techs and electricians.” (Id. at 79, Ins. 7-10.) Denis stated that the addition of certain projects was the only change made to the scope of the project. (Denis Dep., PL’s Ex. X at 77, Ins. 9-16.) Although Vitucci argues in his Sur-Reply that the scope of the project never changed (see PL’s Amend. Sur-Reply at 35), in his deposi-' tion he admitted that the scope of the project did in fact increase (Vitucci Dep., PL’s Ex. U at 79, Ins. 9-11). D. Facts Relating to Richard E. Thomas Plaintiff Richard E. Thomas is African American and was fifty years old in 2001. (Thomas Dep., PL’s Ex. T, “Ex. 1.”) He was hired at Fairless Works in 1972. (CompLI 10.) By 2001, Thomas held the non-union position of facility manager. (Thomas Dep., PL’s Ex. T at 36, Ins. 22-23.) On the Roster prepared by Jones, Thomas’s name was listed on the “Others Not Included Above” list, with the comment “Pension” and a rating of “4A” (out of a possible high of eight) next to his name. (Jones Dep., PL’s Ex. F, “Jones Ex. 1.”) At U.S. Steel, a rating of four indicates satisfactory performance and is considered to be an average acceptable score. (See supra note 9.) Thomas holds a bachelor’s degree in urban studies and a master’s degree in library and information science from the University of Pittsburgh. (Thomas Dep., PL’s Ex. T at 6, In. 21-7, In. 14.) Over the course of his employment, Thomas was given various performance increases (Thomas Dep., Ex. T at 115, Ins. 18-23), was relocated to other facilities within the company in various capacities (id. at 45, Ins. 7-20), and, as facility manager of sheet finishing, “shared duties and learned the responsibilities for both the Galvanized Line as a line supervisory [sic ] and the warehouse, finishing warehouses and the sheet temper mill” (id. at 38, Ins. 10-22). As a result, Thomas felt that he would have been qualified to work on the Galvanized Line. (Id. at 116, Ins. 3-17.) Kennedy testified that Thomas could have been qualified to fill some position on the Galvanized Line, although Kennedy qualified his statement with the admission that he had not “look[ed] at ... all of the records” before making this assessment. (Kennedy Dep., PL’s Ex. H at 87, Ins. 8-10.) Kennedy did not address Jones’s assertion that those with technical backgrounds were superior candidates for retention than those without. Jones indicated that he would have considered Thomas as a candidate for the Galvanized Line if the other candidates he had preselected had not been available. (Jones Dep., PL’s Ex. F at 185, Ins. 8-19.) During the VERP election period, Thomas concluded that U.S. Steel would not retain him after the closure. He testified: “There were things going on in the plant, Dennis Jones having meetings with the younger guys, excluding me from those meetings. These younger guys who are being positioned by, given specific training that were [sic] not being given to me. These were all indications. I’ve been around this company long enough. I know the culture. When you’re about to be excluded, certain things happen. Like the changing of my evaluation [down two points from the previous evaluation] ...” (Thomas Dep., PL’s Ex. T at 76, In. 19-77, In. 3.) During the VERP election period, Thomas spoke with his immediate supervisor, Gary Pirozzola (“Pirozzola”), about “this so-called list or people’s understanding that people were already being selected or appointed or told they were going to be retained.” (Id., at 74, In. 23-75, In. 2.) According to Thomas, Pirozzola told him that “it would be within [Thomas’s] best interest to take the VERP. And having been around long enough and having experienced this kind of stuff before, no more had to be said.” (Id. at 75, Ins. 14-21.) Kennedy acknowledges that Thomas spoke to him about Thomas’s “feeling that management wanted to keep the younger ... employees.” (Kennedy Dep., PL’s Ex. H at 98, Ins. 8-16.) According to Kennedy, his reply to Thomas was “something to the effect [of,] I wouldn’t go so far as to say that.” (Id. at 100, Ins. 14-15.) According to Thomas, he asked Kennedy directly, “Bob, you don’t have a job for me, do you” (Thomas Dep., PL’s Ex. T at 78, Ins. 14-15), to which Kennedy “sheepishly put his head down as if [Thomas] had put him on the spot” (id. at 79, Ins. 1-2), “ignored the question” and “did not answer” (id. at 78, Ins. 14-16). Thomas was given a document that estimated that he would receive $581,182 in pension benefits with the VERP, compared to $422,970 without. (Id., “Ex. 1.”) Thomas accepted the VERP on October 31, 2001, at age fifty. (PL’s Second Amend. Resp. at 21; Thomas Dep., PL’s Ex. T, “Ex. 1.”) All three of the African Americans who had been employed at Fairless Works prior to the announced shutdown, including Thomas, elected to participate in the VERP. (Pl.’s Second Amend. Resp. at 44.) As a result, no African Americans remained at Fairless Works after the VERP election period. (Id.) Of the sixteen managerial employees who did not elect the VERP and were retained, all were Caucasian. (Def.’s Resp. to Pl.’s Interrogs., PL’s Ex. N., “Ex. D.”) Eleven of the sixteen who were retained were at least five years younger than Thomas (ranging from twenty-five to forty-three years of age); five of these employees, ranging from forty-six to fifty-one years of age, were close to Thomas’s age or slightly older. (Id.) II. Legal Standard “[S]ummary judgment should be granted if, after drawing all reasonable inferences from the underlying facts in the light most favorable to the non-moving party, the court concludes that there is no genuine issue of material fact to be resolved at trial and the moving party is entitled to judgment as a matter of law.” Kornegay v. Cottingham, 120 F.3d 392, 395 (3d Cir.1997). An issue of fact is genuine where “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). III. Discussion 1. Age discrimination under the ADEA Two types of employment discrimination claims can be brought under the ADEA: claims of disparate treatment and claims of disparate impact. See Smith v. City of Jackson, 544 U.S. 228,-, 125 S.Ct. 1536, 1539, 161 L.Ed.2d 410 (2005). In a disparate treatment claim, the plaintiff must ultimately show that his age “ ‘actually motivated’ or ‘had a determinative influence on’ the employer’s adverse employment decision.” Fasold v. Justice, 409 F.3d 178, 183-84 (3d Cir.2005). In a disparate impact claim under the ADEA, the plaintiff challenges a specific, facially neutral employment practice that operates to “deprive [the] individual of employment opportunities or otherwise adversely affect his status as an employee.” Smith, 125 S.Ct. at 1542. In such a claim, the plaintiff must show that the practice has an adverse impact on older workers that is not due to reasonable factors other than age. Id. at 1545. Here, the plaintiffs bring both types of discrimination claims against U.S. Steel. I will analyze first their claims of disparate treatment, then their claims of disparate impact. A. Disparate treatment Disparate treatment may be proven by direct evidence or indirect evidence. Here, the plaintiffs offer indirect evidence of age discrimination. Thus, their claims must proceed through the three-step burden-shifting framework established by McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). The first step is for the plaintiff to establish a prima facie case of age discrimination, which creates an inference that the employer acted with a discriminatory motive. McDonnell Douglas, 411 U.S. at 802, 93 S.Ct. 1817. The burden then shifts to the defendant to produce evidence that it had a legitimate business reason for its adverse employment action. Id. at 802-03, 93 S.Ct. 1817. If the defendant does so, the inference of discriminatory motive is dispelled and the burden shifts back to the plaintiff to show that the defendant’s articulated reason is merely a pretext for intentional discrimination. Id. at 803, 93 S.Ct. 1817. Although the burden of production may shift, the ultimate burden remains with the plaintiff at all times to prove that the employer’s adverse employment action was intentionally discriminatory. Texas Dep’t of Community Affairs v. Burdine, 450 U.S. 248, 253, 101 S.Ct. 1089, 67 L.Ed.2d 207 (1981). In order to satisfy the first step of the McDonnell Douglas framework, the plaintiff must make a prima facie showing that: 1) he is within the protected class, i.e., is over forty; 2) he was qualified to have been retained; 3) he suffered from an “adverse employment action”; and 4) the employer retained a “sufficiently younger” and “similarly situated” individual to permit a reasonable inference of age discrimination. Anderson v. Consol. Rail Corp., 297 F.3d 242, 249-50 (3d Cir.2002). A plaintiff who cannot make a prima facie showing of each of these elements cannot survive summary judgment. Each of the plaintiffs’ disparate treatment claims fails, although for different reasons. Embrico, Vitucci, and Williams each fail to establish the third element of the prima facie case — that they suffered an adverse employment action. I will address their claims first. Thomas, unlike the other three plaintiffs, has made out a prima facie case under the McDonnell Douglas framework. As I will discuss below, his disparate treatment claim ultimately fails to survive summary judgment, as he is unable to carry his complete burden under the burden-shifting framework of McDonnell Douglas. 1. Nick Embrico Embrico has failed to show that he suffered an adverse employment action because he has failed to show that his retirement was involuntary. Here, Embrico argues that his decision to take early retirement was coerced by the knowledge that he would be fired if he did not retire, such that he suffered a “constructive discharge.” “The test applied to constructive discharge claims is objective: whether a reasonable jury could conclude that [the employer] permitted conditions so unpleasant or difficult that a reasonable person would have felt compelled to resign.” Connors v. Chrysler Fin. Corp., 160 F.3d 971, 974 (3d Cir.1998). The employer must “knowingly” permit these conditions. Gray v. York Newspapers, 957 F.2d 1070, 1082 (3d Cir.1992) (internal citations omitted). “An employee is protected from a calculated effort to pressure her into resignation through the imposition of unreasonably harsh conditions, in excess of those faced by her co-workers.” Id. at 1083 (internal citations omitted). The “intolera-bility” of such conditions “is not established by showing merely that a reasonable person, confronted with the same choices as the employee, would have viewed resignation as the wisest or best decision, or even that the employee subjectively felt compelled to resign; presumably every resignation occurs because the employee believes that it is in his best interest to resign. Rather, [ijntolerability ... is assessed by the objective standard of whether a ‘reasonable person’ in the employee’s position would have felt compelled to resign — that is, whether he- would have had no choice but to resign.” Connors, 160 F.3d at 976 (quoting Blistein v. St. John’s College, 74 F.3d 1459 (4th Cir.1996)) (emphasis in original). The Third Circuit cites with approval the approach of the Seventh Circuit, which frames the voluntariness issue as “turn[ing] on such things as: did the person receive information about what would happen in response to the choice? was the choice free from fraud or other misconduct? did the person have an opportunity to say no?’ ” Gray, 957 F.2d at 1081 (quoting Henn v. Nat’l Geographic Soc’y, 819 F.2d 824, 828-29 (7th Cir.1987)). Embrico admits that none of the senior management staff gave him any indication either way about what his job prospects might be after the closure. (Embrico Dep., Pl.’s Ex. R at 42, In. 15-43, In.' 7.) According to Embrico, his belief that he would be fired if he did not voluntarily retire was based primarily on Division Manager Coon’s statement that U.S. Steel was planning to close the departments under Embrico’s management (id. at 39, In. 12MD, In. 23) and the fact that, unlike past VERPs,. during this VERP he was. not asked what his preferences for transfer would be (id. at 49, Ins. 17-22). From these two items, Embrico concluded that U.S. Steel “didn’t leave me any options” but to retire. (Id. at 67, Ins. 9-11.) While these facts show that Embrico faced a very difficult decision regarding early retirement, they fail to rise to the level of constructive discharge. In Gray v. York Newspapers, the plaintiff Gray alleged that she had been forced to retire because the employer offered her early retirement “out of the clear blue sky,” had threatened in the past to remove her from her long-time job assignment, had falsely reassured her about her current job security, and had “harassed” and “forced out” two of her co-workers. 957 F.2d at 1081, 1074. The court in Gray held that even if it accepted these allegations as true, they did not suffice to prove that Gray would have been unlawfully terminated had she not .accepted early retirement. The court found that the plaintiff had .“deliberated her options carefully” and voluntarily chose to accept the early retirement package. Id. at 1082-83. Similarly, in Connors v. Chrysler Financial Corp., the court ruled that the plaintiff failed to show an adverse employment action where the plaintiff, whose employer was being bought out by another company, received “the same general offer of employment that every other employee of [his company] received” and decided to retire early after a difficult deliberation between early retirement or an “uncertain future” at the new company. 160 F.3d at 975. The court found that the plaintiffs decision to retire was “an informed decision based on economic realities,” rather than a constructive discharge. Id. at 974. The plaintiff was “not fleeing from a stick, [he] was reaching for a carrot.” Id. at 975. Under Gray and Connors, to establish constructive discharge Embrico must show more than general uncertainty; he must show that the employer knowingly permitted such unpleasant or difficult conditions that a reasonable person in his position would feel “compelled” to retire. Connors, 160 F.3d at 974. Making all reasonable inferences in Embrico’s favor, one might conclude that Embrico’s position would not have survived the closure of the Tin Line, that he had not been asked about his transfer preferences as he had been in the past, and that he was not among the handful who were rumored to have been reassured about their futures at the plant. On the other hand, based upon Embrico’s long and varied work experience at the plant, he reasonably believed he had great potential to be reassigned. Further, Embrico does not dispute that U.S. Steel refused to publicly disclose during the VERP election period how many positions would remain after the closure nor what criteria would be used in filling them. He does not contest that he received the same offer of VERP enhancements as other employees with comparable work histories. Thus, while the facts show that a reasonable person in Embrico’s position might view resignation as “the wisest or best decision,” Connors, 160 F.3d at 976, they do not show that termination was objectively so certain that he had no choice but to retire. Ultimately, the facts show that Embrico made an informed, voluntary choice to take the enhancements available under the VERP rather than face the serious risk of being laid off. Because Embrico has failed to allege facts that rise to the level of constructive discharge, he has faded to show that he suffered any adverse employment action by his employer. As a result, his claims under the ADEA cannot prevail. 2. Frank Vitucci Similarly, Vitucci has failed to show that he was constructively discharged. Again, even taken in the light most favorable to the plaintiff, the facts surrounding Vituc-ci’s decision to take the VERP establish uncertainty at best. Vitucci admitted that Kennedy, Coon and Jones pled ignorance when he inquired about his job situation, and that no one advised him to take the VERP. (Vitucci Dep., Pl.’s Ex. U at 39, Ins. 12-18; id. at 59-60.) He testified that Coon “hinted ... in a roundabout way without saying it” that his position would no longer exist after the closure, which “led [me] to believe I wouldn’t have a job.” (Id. at 38, Ins. 18-22; id. at 44, Ins. 21-22.) However, like Embrico, Vitucci believed himself to be eligible to be reassigned, due to his varied experience at the plant. (Id. at 67, Ins. 12-17.) Also like Embrico, Vi-tucci had no way of knowing from U.S. Steel’s disclosures how many positions would remain after the closure nor what criteria would be used to fill them. In essence, Vitucci argues that the lack of definite positive indications about his future should be sufficient to prove constructive discharge. Taken as a whole, the evidence establishes that Vitucci’s future at Fairless Works was quite simply unknowable at the time he took the VERP. Like Embrico, Vitucci’s evidence shows that a reasonable person in his position would have reason to think he might be retained, but also reason to think he might not be retained. This proffer falls short of the showing necessary to show constructive discharge — that is, it fails to show more than uncertainty. Thus, for similar reasons as Embrico, Vi-tucci has failed to prove constructive discharge and his claims under the ADEA must fail. 3. Roy Williams As with Embrieo and Vitucci, Williams has presented insufficient facts to show constructive discharge. Like Embrieo and Vitucci, Williams admits that no one advised him to take the VERP and that neither of the two supervisors with whom he spoke gave him any indication “one way or the other” whether he would be retained after the closure. (Williams Dep., Pl.’s Ex. S at 38-43.) He admits that U.S. Steel did not take any direct action to encourage or induce him to retire. Instead, like Vitucci, he argues that U.S. Steel’s failure to affirmatively reassure him made it clear that he had to retire. It may well be that U.S. Steel’s refusal to promise Williams a job after the closure gave him reason to feel uncertain and concerned, particularly given the rumors he had heard that some employees had been reassured. However, even making these reasonable inferences in his favor, Williams has not met the standard articulated in Gray and Connors: that his employer permitted conditions so intolerable that a reasonable person in his position would have felt compelled to retire. Thus, his claims under the ADEA must fail. 4. Richard Thomas Thomas’s disparate treatment claim under the ADEA fails as well. Unlike the other three plaintiffs, Thomas satisfies all four elements necessary to make out a prima facie case of intentional discrimination. Ultimately, however, he does not rebut the defendant’s assertion that a legitimate, non-discriminatory reason motivated its adverse employment action. Thomas’s disparate treatment claim therefore fails the last step of the three-step McDonnell Douglas framework and cannot survive summary judgment. i. Thomas’s prima facie case Thomas has made a prima facie showing that he suffered an adverse employment action. Although his proof of constructive discharge is not very strong, Thomas has asserted particularized facts that go beyond the rumored handful of secret meetings and general uncertainty alleged by the other three plaintiffs. Specifically, Thomas offers his testimony that younger employees were given trainings from which he was excluded; that his latest evaluation had been lowered two points unexpectedly; that his immediate supervisor, Gary Pirozzola, directly recommended to him that he accept the VERP; and that when he directly confronted Kennedy about his imminent termination, Kennedy was silent in such a way that it could reasonably be interpreted as an affirmation. (See supra at 18.) Further, according to Kennedy’s testimony, when Thomas expressed his view to Kennedy that “management wanted to keep the younger ... employees,” Kennedy did not clearly disabuse Thomas of the notion, but merely stated that he “wouldn’t go so far as to say that.” (Kennedy Dep., Pl.’s Ex. H at 98, Ins. 8-16; id. at 100, Ins. 14-15.) This statement could reasonably be interpreted as admitting the essence of Thomas’s statement and merely quibbling over its characterization. These additional facts asserted by Thomas tend to give an objectively reasonable basis for Thomas’s belief that he would be fired after the Tin Line closure if he did not retire. Direct recommendations by supervisors to retire may support a plaintiffs belief that he would have been terminated if he had not retired. See, e.g., Wilkins v. ABF Freight Sys., Inc., Civ. A. No. 03-6610, 2005 WL 2271866 at *5 (E.D.Pa. Sept. 15, 2005) (plaintiffs showing of constructive discharge was sufficient to survive a motion to dismiss, where plaintiff alleged that his employer had repeatedly urged him to retire and at times had threatened him with discharge if he did not retire). Thomas’s alleged exclusion from trainings and the unexpected lowering of his performance rating provide further support for his theory of constructive discharge. Courts have found that a poor performance rating “coupled with evidence that the employer has used it to the plaintiffs detriment may be considered an adverse employment action.” Allen v. Verizon Pennsylvania, Civ. A. No. 04-1515, 2005 WL 2035858 at *10 (M.D.Pa. Aug. 23, 2005). Here, Thomas’s testimony may support a reasonable inference that U.S. Steel was deliberately positioning him so that he would not be qualified for retention, or alternatively, that U.S. Steel was knowingly signaling to him that he would not be retained. It is unlikely that any of these facts standing alone would be sufficient to establish a prima facie showing of constructive discharge. Even taken together, they are not very strong evidence. However, Thomas’s deposition as a whole contains “more than ‘a scrap of evidentiary material to support his argument,’ ” which may be sufficient to overcome summary judgment on an issue. Jackson v. Univ. of Pittsburgh, 826 F.2d 230, 234 (3d Cir.1987) (reversing a grant of summary judgment where the facts alleged in plaintiffs lengthy deposition sufficiently called into question the employer’s legitimate, nondiscriminatory reason for firing plaintiff). Although Thomas’s case of constructive discharge is close to the line, I find that he has made at least a prima facie showing of constructive discharge and I will continue to examine his claims under the ADEA in further detail. Thomas argues, and U.S. Steel does not contest, that he has established the other elements of his prima facie case. First, it is undisputed that at age fifty when he accepted the VERP, Thomas was within the protected class of individuals over 40 years of age. Thomas has' also made a prima facie showing that he was qualified to be retained. He presented evidence that his latest performance rating was within the satisfactory range. (Jones Dep., Pl.’s Ex. F, “Jones Ex. 1.”) He testified that he had gained supervisory experience at Fairless Works (Thomas Dep., Pl.’s Ex. T at 115, Ins. 18-23; id. at 38, Ins. 10-22) and had received performance increases over the years {id. at 45, Ins. 7-20). Kennedy testified that Thomas could have been qualified to fill a position on the Galvanized Line. (Kennedy Dep., PL’s Ex. H at 87, Ins. 8-10.) Jones testified that Thomas could have been a candidate for the Galvanized Line, albeit ranked lower than those whom Jones had pre-selected. (Jones Dep., PL’s Ex. F at 185, Ins. 17-19.) Taken together, this evidence shows that Thomas was at least arguably qualified to be retained. Third, Thomas has made a prima facie showing that those who were retained were sufficiently younger and similarly situated. Thomas has shown that the individuals who were retained were “sufficiently, younger to permit a reasonable inference of age discrimination.” See O’Connor v. Consol. Coin Caterers Corp., 517 U.S. 308, 312-13, 116 S.Ct. 1307, 134 L.Ed.2d 433 (1996). “[Tjhere is no particular age difference that must be shown, but while different courts have held ... that a five year difference can be sufficient, ... a one year difference cannot.” Showalter v. Univ. of Pittsburgh Med. Ctr., 190 F.3d 231, 236 (3d Cir.1999). Here, while two of the sixteen who were retained were one year older than Thomas, the remaining fourteen were all at least one year younger than Thomas, with eleven of the sixteen at least five years younger. (See Def.’s Resp. to Pl.’s Inter-roga., Pl.’s Ex. N, “Ex. D.”) Second, Thomas has made a prima facie showing that the sixteen who were retained were “similarly situated” to him. They were all “management-level employees” like himself (CompU 42), and the evidence Thomas offered as to his qualifications is sufficient to show that he was at least arguably comparable in quality and type to the employees who were retained. Thus, I find that he has made a prima facie case that he was replaced by individuals who were both sufficiently younger and similarly situated. ii. U.S. Steel’s Legitimate, Nondiscriminatory Reason Under McDonnell Douglas, once the plaintiff has made out his prima facie case, the burden of production then shifts to the defendant, who can “dispel the inference of unlawful discrimination” by articulating a legitimate, nondiscriminatory reason for its adverse employment decision. Gray, 957 F.2d at 1078. “[T]he employer need only produce admissible evidence which would allow the trier of fact rationally to conclude that the employment decision had not been motivated by discriminatory animus.” Burdine, 450 U.S. at 257, 101 S.Ct. 1089. This is a “relatively light burden.” Fuentes v. Perskie, 32 F.3d 759, 763 (3d Cir.1994). Here, U.S. Steel makes two defenses. First, U.S. Steel presents its own evidence to contest Thomas’s claim of constructive discharge, arguing that it should not have to provide a legitimate reason for Thomas’s constructive discharge because Thomas was never constructively discharged in the first place. U.S. Steel’s position is that even if Thomas has made a prima facie showing of constructive discharge, once its rebuttal evidence is considered, Thomas’s claim of constructive discharge cannot stand. U.S. Steel points to the circumstances surrounding its offer of the VERP, particularly its need to reduce the workforce in anticipation of the Tin Line closure and its offer of enhanced benefits under the VERP to all sixty-four eligible employees, a group that spanned a wide age range. U.S. Steel also disputes Thomas’s factual assertion that Jones held secret meetings with managers in order to advise them not to take the VERP, offering admissible testimony to contradict this assertion. (See supra note 6.) Given these circumstances, U.S. Steel argues, no reasonable jury could find that Thomas was constructively discharged. However, U.S. Steel fails to controvert Thomas’s factual claims that he was denied trainings that were given to younger workers, that his performance rating was unjustifiably lowered, and that he was directly advised to take the VERP. Thus, even after considering the defendant’s rebuttal evidence, I find that there remains a genuine issue of fact as to whether Thomas was constructively discharged. Ultimately, however, because Thomas fails to carry his burden under the third step of the McDonnell Douglas framework, this issue of fact turns out to be insufficient to defeat U.S. Steel’s motion for summary judgment. U.S. Steel’s second defense is that if Thomas were constructively discharged, it was because he lacked a technical background, not because of his age. In support of this argument, U.S. Steel has offered Jones’s testimony that those with a technical background would be best suited to manage the Galvanized-only Line and that Thomas lacked this background. (See Jones Dep., Pl.’s Ex. F at 60, In. 12-61, In. 7.) Because U.S. Steel has articulated and provided evidentiary support for a legitimate, non-discriminatory reason for failing to retain Thomas, the burden of production then shifts back to Thomas. iii. Thomas’s Evidence of Pretext At the third step in the McDonnell Douglas framework, it is the plaintiffs burden to “proffer evidence that is sufficient to allow a reasonable finder of fact to find by a preponderance of the evidence that the employer’s proffered reasons are false or pretextual.” Fasold, 409 F.3d at 184. Under Fuentes v. Perskie, the plaintiff may show pretext in either one of two ways: (1) by offering evidence from which a fact-finder could disbelieve the employer’s articulated legitimate reasons, finding them to be post hoc fabrications or otherwise not really motivating the employment action; or (2) by offering evidence from which a fact-finder could believe that an “invidious discriminatory reason” was more likely than not a motivating or determinative cause of the employer’s action. 32 F.3d at 764. Thomas has offered a body of evidence that he argues is sufficient to establish pretext under either option available under Fuentes. I will consider this body of evidence separately under each option. Fuentes’s first option is to provide evidence sufficient for a fact-finder to disbelieve the defendant’s articulated reason. A plaintiff who seeks to prove pretext under Fuentes’s first option must show “not merely that the employer’s proffered reason was wrong, but-that it was so plainly wrong that it cannot have been the employer’s real reason.” Keller v. Orix Credit Alliance, 130 F.3d 1101, 1109 (3d Cir.1997). He must “demonstrate such weaknesses, implausibilities, inconsistencies, incoherencies, or contradictions in the employer’s proffered legitimate reasons that a reasonable factfinder could find them ‘unworthy of credence ...’” Fuentes, 32 F.3d at 764-65 (citations omitted). Here, Thomas offers no Keller-type evidence to show that Jones’s reliance on technical background was so plainly wrong that it could not have been the real reason. He does not contest that those whom Jones pre-selected possessed a technical background. He does not contest that he lacks this background. Nor does Thomas offer any evidence to suggest that, in fact, technical backgrounds are not helpful or advantageous for the positions on the Galvanized Line. He merely makes a conclusory statement that it is “unbelievable” that “only engineers with technical backgrounds were qualified to operate the mill.” (PL’s Amend. Sur-Reply at 13.) This unsupported opinion is insufficient to discredit U.S. Steel’s asserted legitimate reason for failing to pre-select him. Next, I will consider Thomas’s evidence under Fuentes's second option for proving pretext. Under this option, the plaintiffs burden is to show that invidious discrimination was more likely than not a motivating or determinative factor in the defendant’s adverse employment action. In other words, [t]he plaintiff must point to evidence with sufficient probative force that a factfinder could conclude by a preponderance of the evidence that age was a motivating or determinative factor in the employment decision. For example, the plaintiff may show that the employer has previously discriminated against her, that the employer has discriminated against other persons within the plaintiffs protected class or within another protected class, or that the employer has treated more favorably similarly situated persons not within the protected class. Simpson v. Kay Jewelers, Div. of Sterling, Inc., 142 F.3d 639, 644-45 (3d Cir.1998). In the instant case, Thomas offers a number of arguments in an effort to show that his proof of invidious discrimination is sufficient to go to the jury. One of Thomas’s arguments is that U.S. Steel treated more favorably similarly situated persons outside the protected class (i.e., individuals under 40 years of age). In determining whether an individual is similarly situated to a plaintiff, Simpson v. Kay Jewelers establishes the proper focus. “[T]he focus is on the particular criteria or qualifications identified by the employer as the reason for the adverse action ... The employee’s positive performance in another category is not relevant ... and neither is the employee’s judgment as to the importance of the stated criterion.” Simpson, 142 F.3d at 647 (emphasis added). In Simpson, the employer claimed that it had demoted Simpson because she “repeatedly failed to attain the store sales quotas and failed to adequately train and motivate her staff to meet quotas.” Id. at 645. Simpson sought to prove that the asserted reason was merely a pretext for invidious discrimination by showing that a similarly situated younger manager had not been demoted or fired. Simpson did not dispute that the younger manager’s sales quota performance was superior to hers, but instead argued that the younger manager was similarly situated because her evaluation scores were equal to or lower than Simpson’s. Id. Implicitly, Simpson argued that evaluation scores were more indicative of performance than sales quotas. Id. at 647. However, the court rejected this argument and refused to “subjectively weigh factors it considers important.” Id. at 647. Rather, the court focused solely on the employer’s stated criterion, sales quotas, and found that Simpson failed to meet that criterion. Id. Thus, the court concluded, Simpson had not shown that she was similarly situated to the younger manager, and neither Simpson’s evidence of her high achievement in regards to other criteria nor her personal judgment that the employer’s criterion was actually unimportant were sufficient to raise a genuine issue of material fact. Id. at 647-649. As in Simpson, Thomas seeks to show pretext under Fuentes’s second option by showing that U.S. Steel treated younger, similarly situated workers preferentially. Thomas argues that those who were retained were both younger and similarly situated to him, yet U.S. Steel treated them more favorably by pre-selecting them for retention. But Thomas has failed to rebut U.S. Steel’s argument that the individuals who were pre-selected for retention were more qualified than Thomas because they possessed a technical background that Thomas lacked. (See Jones Dep., Pl.’s Ex. F at 60, Ins. 12-24.) In his discussion of his qualifications, Thomas focuses on his extensive work experience at Fairless Works and his resultant trainability. (See Pl.’s Second Amend. Resp. at 34-35, quoting Thomas Dep., Pl.’s Ex. T at 115, In. 14-116, In. 17.) Like the plaintiff in Simpson, he is essentially asking the court to subjectively weigh the value of the criterion he identifies (work experience) over the value of the employer’s identified criterion (technical background). As in Simpson, however, it is not r