Jackson contends that Plaintiffs have failed to establish the second element of a prima facie case of age discrimination. Jackson argues that Plaintiffs failed to establish they were qualified for retention at its King of Prussia office because the remaining positions were geared towards sales and marketing, Plaintiffs' prior positions involved new business processing and Plaintiffs admit that they have no sales and marketing experience. Plaintiffs argue that Jackson should have trained them for these sales and marketing positions because of Plaintiffs' intimate familiarity with insurance products. Plaintiffs also assert that this familiarity made them more qualified than the young supervisors who were retained. Plaintiffs have failed to establish that they were qualified.
Plaintiffs admit that they had no sales and marketing experience.
They attempt to show that a position at the King of Prussia office after Project Leapfrog did not require sales and marketing experience by arguing that the young supervisors lacked sales and marketing experience. Plaintiffs, however, submit only bald unsubstantiated assertions as evidence to show that the young supervisors who were retained lacked sales and marketing experience. These assertions actually show that at least one of the young supervisors may have had some sales and marketing experience. There simply is no genuine issue of material fact as to whether Plaintiffs were qualified for retention. Plaintiffs argue that Jackson retained young supervisors at its King of Prussia office after Project Leapfrog even though Plaintiffs had more insurance experience.