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Unwanted sexual attention on the Internet occurs when a harasser uses direct personal communication to harass a victim.Additionally, the harasser uses personal communication to convey messages directly relating to sex and/or sexuality which are unwanted or unwelcome by the victim.

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Another common form of Internet harassment occurs when a victim is subject to unwanted, abusive, threatening or obscene messages and/or comments on internet forums, blogs, and discussion boards.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.In 1993, Blakey filed a complaint for sexual discrimination in violation of Title VII of the Civil Rights Act.During litigation, Blakey's co-workers continued to make harassing, gender-based messages aimed at her, which were posted on a company website.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.

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).

Plaintiff, Blakey, became the first female captain to fly an Airbus or A300, qualifying in 1989.

Shortly after her appointment, she complained of conduct and comments directed at her, including pornographic photos and vulgar gender-based comments about her that appeared in the workplace.

The website was used by Continental employees, including pilots and crew members, and was created for the purposes of learning flight schedules and assignments.