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Gender harassment can be communicated in both verbal and graphic forms.

It is often described as "unwelcome verbal and visual comments and remarks that insult individuals because of their gender or that use stimuli known or intended to provide negative emotions." refers to offensive sexual messages aimed towards a victim that are initiated by a harasser.

Similar to Internet harassment occurring in the workplace, Internet harassment in the education setting has become a vital concern to schools and school districts.

Individuals are increasingly beginning to use the Internet at younger ages and for a wider variety of reasons including in the school setting.

Such offensive messages include gender-humiliating comments, rape threats, and sexual remarks which are unwelcome, and are neither invited nor consensual.

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Plaintiff, Sauerhaft, filed this suit on behalf of his daughter, S.

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.

The forum operated as an online bulletin board where employees could post messages to one another.

The Supreme Court of New Jersey held that harassment outside of the workplace can be actionable.

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