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Divorcing Sexual Harassment from Sex: Lessons from the French

expressly prohibited, nor is it considered to be a form of sex discrimination under Title VII, and is prohibited in only a minority, though a growing number, of states. See L. CAMILLE HÉBERT, EMPLOYEE PRIVACY ... ). 5. See L. Camille Hébert, Sexual Harassment as Discrimination “Because of . . . Sex”: Have We Come Full Circle?, 27 OHIO N.U. L. REV 439, 457-80 (2001) (reviewing cases in which lower courts applied