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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 emergence of Internet mediums as the most common method of communication has introduced new elements into combating sexual harassment in the workplace.

Unwanted sexual attention on the Internet occurs when a harasser uses direct personal communication to harass a victim.

A recent New Jersey Supreme Court case highlights this new territory of employer liability under Title VII for Internet harassment.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.Sexual harassment has been a prevalent issue in our society and in the legal system for over fifty years.The ever-increasing use of the Internet in the past twenty to thirty years has served as a medium for sexual harassment that has, until recently, gone relatively unnoticed.

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