Google has been sued by one of its product managers who says that the company’s internal confidentiality policies violate California labor laws. The suit has been filed with the California Superior Court in San Francisco.

The product manager claims that Google runs an “internal spying program” called “Stop Leaks” in which employees are encouraged to voluntarily report about other employees who leak information. Employees at Google are told not to report any illegal activity inside the company in writing as it can potentially fall into the hands of law enforcement agencies and regulators.

The product manager referred to in the lawsuit as “John Doe” also claims that Google’s internal confidentiality policies prevent its employees from writing a “novel about someone working at a tech company in Silicon Valley.” The lawsuit also says that Google’s Code of Conduct states that “everything at Google” is confidential, with employees prohibited to talk about illegal products and the company’s regulatory law breaking acts in emails. The lawsuit also says that one of Google co-founders clearly said at a company meeting that anyone found leaking confidential information would be terminated from his or her job.

If Google is fined guilty in the lawsuit, it could be fined up to $3.8 billion, with each Google employee getting an additional $14,600 to take home.