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This pressure is often achieved by the use of explicit threats of harm directed towards the victim or relatives and friends of the victim.

The complainant alleged that the University had failed to properly respond to complaints that her daughter had been subjected to sexual harassment on the college campus gossip blog, In its investigation, the New York OCR learned that the student had expressed her concerns about the messages to Hofstra's administration and requested that the University remove the messages and shut down the website.Particularly, the use of the Internet for social networking reasons and use in the school environment has created a dangerous outlet for sexual harassment Furthermore, the United States Department of Education has recognized Internet activity such as sending or showing e-mails, websites, and text messages of a sexual nature to be inappropriate sexual conduct that can potentially be actionable as sexual harassment in violation of Title IX.Plaintiff, Sauerhaft, filed this suit on behalf of his daughter, S.S., in response to three harassing e-mails she received on her school e-mail account as a freshman at Hastings-on-Hudson High School over the course of ten days by a male student in March of 2005. printed out the e-mails and showed them to her guidance counselor who brought the matter to the attention of her supervisor and the school's principal.The male student, also using his school e-mail account sent S. messages based on topics such as her weight and sexual activity. The plaintiff brought this claim against the defendant school district asserting that the harassing e-mails constituted student-student sexual harassment under Title IX. Accordingly, the defendant school district was not held liable.

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