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It is these cases that pose the greatest challenge and these cases that push the limits of hostile work environment law. This is a logical result given that the "severe or pervasive" requirement was designed to "filter out complaints attacking the ordinary tribulations of the workplace, such as the sporadic use of abusive language, gender related jokes, and occasional teasing." Faragher v. Payton left the room only after another employee suddenly entered. Michelle Birchstein, an assembly line worker, began receiving unwanted sexual attention from a co-worker. The woman who struck Jones had previously hit other male employees in the groin.

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