I will attach the full suit, but there is a tight well-written statement of the lawsuit's claim appears in the opening to the lawsuit itself. I will quote it here in its entirety. You should email this to anyone you know who works for Kaiser.

On August 2, 2021, Kaiser Permanente announced that it would mandate that all
of its over 200,000 employees nationwide be vaccinated for the SARS-CoV-2 virus ("COVID"). Doctors, nurses and others within Kaiser have joined Simone as plaintiffs in this lawsuit.

On August 2, 2021, Kaiser Permanente announced that it would mandate that all of its over 200,000 employees nationwide be vaccinated for the SARS-CoV-2 virus ("COVID").

Plaintiffs are Kaiser Permanente doctors, nurses, and support staff. This is their
challenge to that mandate.

Plaintiffs assert that a mandatory vaccine cannot be supported when:

Over 99.8% of all those who are infected and ill with COVID survive.

Those who survive obtain robust and durable natural immunity.

The natural immunity so obtained is superior to COVID vaccine-induced
immunity.

The COVID vaccines are ineffective against the Delta strain of COVID, which the Center for Disease Control ("CDC") states is the dominant (>99%) strain
throughout the United States.