I. Introduction

II. Understanding Title IX in the Context of Sexual Assault ... A. How Davis v. Monroe County Board of Education Advanced Title IX ... B. The Deliberate Indifference Standard Under Title IX and How Courts Are Inconsistently Applying What Is Required as “Further Harassment”

III. Karasek v. Regents of the University of California ... A. Karasek ... B. Commins ... C. Butler

IV. The Northern District of California Correctly Interpreted the Further Harassment Requirement of Title IX Cases

V. The Dear Colleague Letter as an Appropriate Future Requirement

VI. Conclusion