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The Court noted that the conduct at issue arose out of employee relationships and was therefore relevant, regardless of where the harassment occurred.

Furthermore, the Court held that an employer may not disregard offensive messages posted on a company website when the employer is aware or should be aware of the messages.

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.

Verbal harassment can be either passive or active depending on whether the harasser targets a specific victim (active) or targets potential receivers (passive).

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