Full opinion text
MEMORANDUM OPINION CONTI, Chief Judge. This is a civil rights, employment, and common law tort case in which Paul Kahan (“Kahan”) accuses his former employer, Slippery Rock University (“SRU”), several of its individual employees, and the husband and son of one of its employees, of wrongfully either failing to renew his teaching contract, or causing that contract not to be renewed. Under federal law, Kahan asserts gender-based discrimination, retaliation, and hostile work environment claims pursuant to 42 U.S.C. §§ 2000e-2000e-17 (“Title VII”), and 20 U.S.C. § 1681 (“Title IX”), and constitutional claims under 42 U.S.C. § 1983, alleging violations of his equal protection, free speech, and due process rights. Ka-han additionally asserts companion employment discrimination claims under the Pennsylvania Human Relations Act, 43 Pa. Stat. § 951-963 (the “PHRA”), and Pennsylvania common law claims of promissory estoppel, intentional interference with contract, and malicious prosecution, as well as a statutory defamation claim pursuant to 42 Pa. Cons. Stat. § 8341. Kahan seeks injunctive and declaratory relief, compensatory and punitive damages, back and front pay, attorneys’ fees, and all other available damages. SRU, and its co-defendant employees, filed a motion for summary judgment (ECF No. 77.) The co-defendant employees are: (1) Eva Tsuquiashi-Daddesio, Interim Dean of SRU’s College of Humanities, Fine and Performing Arts (“Dean Tsuquiashi-Daddesio”); (2) John Craig, Chairman of SRU’s History Department (“Craig”); and (3) Charlene Winslow, SRU’s History Department’s secretary (“Mrs. Winslow”), (collectively, with SRU, the “SRU Defendants” and collectively, but without SRU, the “Individual SRU Defendants”). The SRU Defendants filed a brief in support of their motion, (ECF No. 78), a concise statement of material facts, (ECF No. 79), an appendix, (ECF No. 80), and a response to Kahan’s coun-terstatement of material facts, (ECF No. 116). Separate motions for summary judgment, and supporting briefs, statements of fact, appendices, and responses to Kahan’s counterstatement of material facts, were filed by Thomas E. Winslow, (ECF Nos. 81-84, and 118), and Thomas M. Winslow, (ECF No. 85-88, and 119). Thomas E. Winslow is Mrs. Winslow’s husband and will be referred to throughout this opinion as “Mr. Winslow.” Thomas M. Winslow is Mr. and Mrs. Winslow’s son, and was a student at SRU during the pertinent time period. He will be referred to throughout this opinion as “Tommy Winslow.” In response to each of the three motions for summary judgment, Kahan filed an opposition brief, appendices, and a statement of material facts that both responded to each movant’s concise statement of material facts and included a separate coun-terstatement of material facts. (ECF Nos. 99-101,103-05,107-09.) After the close of briefing, the parties submitted joint concise statements of material facts for each of the three respective summary judgment motions. (ECF Nos. 120-22.) For the reasons that follow in this memorandum opinion, judgment will be entered against Kahan on each of his federal claims. Because no claim that arises under federal law survives summary judgment, this court declines to exercise supplemental jurisdiction over the Pennsylvania common law and statutory claims. Those claims will be dismissed, without prejudice to Kahan’s right to raise them in state court. I. FACTUAL BACKGROUND All material facts set forth herein are undisputed unless otherwise indicated. Additional material facts may be discussed elsewhere in this memorandum opinion, in context. Because three separate motions for summary judgment are pending, there are three separate combined concise statements of material fact. The combined concise statement of material facts related to the SRU Defendants’ motion for summary judgment, which is docketed at ECF No. 122, will. be referred to in the format “ECF No. 122, SRU CCSMF ¶^” The combined concise statement of material facts related to Mr. Winslow’s motion for summary judgment, which is docketed at ECF No. 120, will be referred to in the format “ECF No. 120, Mr. Winslow CCSMF ¶ x.” The combined concise statement of material facts related to Tommy Winslow’s motion for summary judgment, which is docketed at ECF No. 121, will be referred to in the format “ECF No. 121, Tommy Winslow CCSMF ¶ x.” A. Kahan’s Employment with SRU 1. Non-Renewal of Kahan’s One-Year Contract Kahan was selected for the position of Assistant Professor in SRU’s Department of History in February 2009. (ECF No. 122, SRU CCSMF ¶ 1.) The chairman of the history department, Craig, did not concur with the majority vote of the department, and preferred to hire a different candidate, Daniel Barr, who is also a male. (ECF No. 122, SRU CCSMF ¶¶30, 70; ECF No. 80-5 at 2 (Craig memo).) Kahan was hired to replace a male professor. (ECF No. 122, SRU CCSMF ¶¶ 1, 69.) Kahan’s notice of appointment indicated that he would begin teaching in August 2009, and was a probationary, tenure-track professor whose one-year contract was subject to renewal based upon various conditions, including adherence to the terms of the Collective Bargaining Agreement between the Association of Pennsylvania State College and University Faculties and the Pennsylvania State System of Higher Education (the “CBA”). (ECF No. 122, SRU CCSMF ¶¶ 1-2, 31; ECF No. 80-1 at 43-58(CBA); ECF No. 80-1 at 40-41 (offer letter and appointment notice).) Decisions with respect to renewal of probationary teaching contracts, such as Ka-han’s contract, were based upon evaluations and recommendations made by the history department’s evaluation committee, the history department’s chairman, the dean of the college of humanities, and the provost and president of SRU. (ECF No. 122, SRU CCSMF ¶¶3, 21, 33.) Kahan was entitled to written notice of SRU’s decision with respect to renewal of his one-year contract no later than April 1, 2010. (ECF No. 80-1 at 56-57 (CBA, Art. 14, § A(4)(a)(l)).) Article 12 of the CBA sets forth the standards to be applied when evaluating probationary professors. (ECF No. 122, SRU CCSMF ¶¶3, 32; ECF No. 80-1 at 56 (CBA, Art. 14, § A(3)).) The first evaluation criterion is “effective teaching and fulfillment of professional responsibilities,” the latter of which includes submitting grades and reports in a timely fashion, and attending faculty meetings. (ECF No. 122, SRU CCSMF ¶ 4; ECF No. 80-1 at 48 (CBA, Art. 12, § B(l)).) The other two evaluation criteria are “continued scholarly growth” and “service contributions to SRU or the community.” (ECF No. 80-1 at 48-49 (CBA, Art. 14 § B(2) and (3)).) On February 1, 2010, Craig, as chair of the history department, completed a performance review report, in which he favorably commented on Kahan’s performance in all three areas of evaluation. (ECF No. 80-3 at 18-20 (Craig report); ECF No. 122, SRU CCSMF ¶ 22.) Craig’s report ultimately concluded that Kahan’s contract should be renewed. (Id.) On February 8, 2010, the history department evaluation committee completed its performance review report, in which it evaluated Kahan in the areas of service, scholarship, and teaching. (ECF No. 80-3 at 14-16 (committee report); ECF No. 122, SRU CCSMF ¶22.) The committee’s report was also favorable to Kahan, while noting the recommendation was “tentative” and “preliminary” because Kahan had been teaching at SRU for less than six months at the time of its submission. (ECF No. 80-3 at 15 (committee report); ECF No. 122, SRU CCSMF ¶22.) Based upon these two reports, and supporting materials submitted by Kahan, Dean Tsuquiashi-Daddesio recommended renewal of Ka-han’s one-year probationary teaching contract in a letter to Kahan dated March 2, 2010. (ECF No. 80-3 at 22 (Dean’s letter).) On that same date, Dean Tsuquia-shi-Daddesio notified Dr. William Williams, provost and vice president for academic affairs (“Provost Williams”), of her favorable recommendation. (ECF No. 80-3 at 23 (Dean memo).) Three days later, on March 5, 2010, SRU’s academic records office sent a memorandum to Dean Tsuquiashi-Dadde-sio notifying her that Kahan was the only faculty member within her college who failed to submit spring 2010 semester midterm grades by the March 4, 2010 deadline. (ECF No. 80-3 at 37 (memo); ECF No. 122, SRU CCSMF ¶ 12.) Dean Tsuqui-ashi-Daddesio had not received a similar memorandum from the academic records office concerning Kahan’s submission of mid-term grades for the fall 2009 semester, but came to learn in March 2010 that Kahan only met that deadline because an academic records office staff member, who called Kahan to inform him that his grades were late, agreed to input Kahan’s grades into the computer system on his behalf if he faxed them to the academic records office. (ECF No. 122, SRU CCSMF ¶¶ 7, 141; ECF No. 101^1 at 46-47 (Craig draft memo); ECF No. 101-13 (Kahan decl.) ¶ 28.) March 5, 2010 was the last day that SRU was in session before spring break. (ECF No. 122, SRU CCSMF ¶ 13.) Craig and Dean Tsuquiashi-Daddesio spoke about Kahan’s tardy submission of midterm grades, and other performance problems, on Monday, March 15, 2010, the day that classes resumed at SRU following spring break. (ECF No. 122, SRU CCSMF ¶¶ 13-15, 125.) Craig orally informed Dean Tsuquiashi-Daddesio on March 15, 2010, that he no longer supported renewal of Kahan’s one-year contract. (ECF No. 122, SRU CCSMF ¶ 125.) Following this conversation, Craig sent a draft memorandum to Dean Tsuquiashi-Daddesio, on March 18, 2010, in which he summarized Kahan’s late submission of grades, as well as other deadlines and meetings that Kahan missed during his first year teaching at SRU. (ECF No. 101— 4 at 46^7 (Craig draft memo); ECF No. 122, SRU CCSMF ¶ 127.) Craig’s draft memorandum, which was revised and sent to Dean Tsuquiashi-Daddesio in final form on March 19, 2010, indicated that Craig no longer recommended renewal -of Kahan’s contract based upon Kahan’s “pattern of neglect” in “repeatedly ignoring deadlines during his initial year of employment.” (ECF No. 80-3 at 28-29 (Craig final memo); ECF No. 122, SRU CCSMF ¶ 26.) The March 18, 2010 draft memorandum differs from the March 19, 2010 final memorandum in various respects, including that Craig removed a statement that Ka-han’s behavior “seems to reveal incompetence, a lack of responsibility, arrogance, and other personality issues that collectively explain his inattention to required duties.” (Compare ECF Nos. 101-4 at 46-47 (Craig draft memo) and 80-3 at 28-29 (Craig final memo).) Craig notified the chair of the history department’s evaluation committee about his revised recommendation, and the reasons for it, in a memorandum dated March 23, 2010. (ECF No. 105-2 at 45 (Craig memo).) Dean Tsuquiashi-Daddesio spoke with Provost Williams by telephone on or around March 23, 2010, to notify him that she no longer supported the renewal of Kahan’s one-year probationary teaching contract, and to explain why she changed her recommendation. (ECF No. 122, SRU CCSMF ¶ 167.) Following this conversation, Provost Williams notified Dr. Robert M. Smith, President of SRU (“President Smith”), in a memorandum dated March 23, 2010, that he was not recommending renewal of Kahan’s contract. (ECF Nos. 80-3 at 33 (Williams memo) and 101-5 at 21 (Williams email); ECF No. 122, SRU CCSMF ¶¶ 40-41, 164-65, 167.) Dean Tsuquiashi-Daddesio memorialized her withdrawal of support for Kahan’s renewal, and the reasons for it, in a memorandum to Provost Williams, dated March 25, 2010. (ECF No. 80-3 at 31 (Dean memo); ECF No. 122, SRU CCSMF ¶¶40, 160.) President Smith notified Kahan by letter dated March 30, 2010, that SRU would not renew his contract for the 2010-2011 academic year, and that his appointment would expire on June 4, 2010. (ECF No. 80-3 at 35 (Smith letter); ECF No. 122, SRU CCSMF ¶ 41.) Pursuant to the CBA, Kahan was entitled to receive notice of SRU’s decision with respect to renewal of his contract no later than April 1, 2010. (ECF No. 80-1 at 56 (CBA, Art. 14, § A(4) (a)(1)).) Craig met with Kahan, in person, on March 23, 2010, to discuss Kahan’s performance problems and to inform Kahan that Craig no longer supported renewal of his contract. (ECF No. 122, SRU CCSMF ¶ 15; ECF No. 105-2 at 45 (Craig memo); ECF No. 109-3 at 39 (Craig email); ECF No. 80-3 at 40 (Kahan memo) (indicating date of meeting with Craig as March 22, 2010).) Craig provided Kahan a copy of the memorandum that he sent to the history department’s evaluation committee, which was dated. March 23, 2010, on the same day that they met. (ECF No. 105-2 at 45 (Craig memo); ECF No. 109-3 at 39 (Craig email).) According to Kahan, he never received a copy of the draft or final memoranda that Craig sent to Dean Tsuquiashi-Daddesio on March 18 and 19, 2010. (ECF No. 122, SRU CCSMF ¶ 37.) Kahan first learned that Dean Tsuquia-shi-Daddesio no longer supported renewal of his contract during a previously-scheduled March 25, 2010 meeting. (ECF No. 122, SRU CCSMF ¶ 168.) At this meeting, Dean Tsuquiashi-Daddesio showed Kahan a draft of her March 25, 2010 memorandum to Provost Williams, which was dated March 23, 2010, but refused to give Kahan a copy of it. (ECF No. 122, SRU CCSMF ¶ 168-69.) This draft version of Dean Tsuquiashi-Daddesio’s memorandum included a reference to a complaint letter that Mrs. Winslow submitted to Craig about Kahan; however, the final version of Dean Tsuquiashi-Daddesio’s memorandum does not include this reference. (Compare ECF Nos. 101-5 at 4 (Dean draft memo) and 80-3 at 31 (Dean final memo); ECF No. 122, SRU CCSMF ¶ 160; ECF No. 80-3 at 47-48 (Mrs. Winslow complaint letter).) Kahan is copied on the final version of Dean Tsuquiashi-Daddesio’s March 25, 2010 memorandum. (ECF No. 80-3 at 31 (Dean final memo).) Dean Tsuquiashi-Daddesio, Craig, and the history department evaluation committee provided Kahan with opportunities to discuss the evaluations and recommendations before President Smith issued his final non-renewal decision on March 30, 2010. (ECF No. 122, SRU CCSMF ¶ 42.) In particular, Kahan submitted a memorandum to Provost Williams, dated March 28, 2010, in direct rebuttal to Dean Tsuqui-ashi-Daddesio’s March 25, 2010 memorandum to Provost Williams, and met or personally spoke with Provost Williams at least twice between March 29, 2010 and April 5, 2010. (ECF No. 122, SRU CCSMF ¶¶ 42, 172-73; ECF No. 80-3 at 39-42 (Kahan memo); ECF No. 101-5 at 21 (Kahan email).) Kahan also appeared before the history department’s evaluation committee on March 29, 2010 to plead his case. (ECF No. 122, SRU CCSMF ¶¶ 38, 172-73; ECF Nos. 80-3 at 25-26 (committee memo).) The evaluation committee submitted a memorandum to Provost Williams, dated March 30, 2010, in which it confirmed its original recommendation in favor of renewal of Kahan’s contract, “but with reservations in light of his noted mistakes.” (ECF No. 80-3 at 25-26 (committee memo).) Craig sent a memorandum to Dean Tsuquiashi-Daddesio the following day, March 31, 2010, in which he stated that he hoped the evaluation committee’s recommendation would receive “careful consideration,” but that he remained personally opposed to renewal of Kahan’s contract. (ECF No. 101-5 at 18 (Kahan memo).) Kahan asked Dean Tsuquiashi-Daddesio, by email dated March 31, 2010, if she would reconsider her recommendation that his contract not be renewed in light of the evaluation committee’s continued support of his renewal, but Tsuquia-shi-Daddesio refused to do so because the committee “added ‘with reservations’ to its original recommendation” and Craig notified her that he remained opposed to renewal. (ECF No. 101-5 at 20 (Kahan-Dean emails).) When Kahan emailed Craig on April 1, 2010, about Craig’s refusal to support renewal of his contract, Craig responded that “it was your decision to seek and secure adjunct work and then miss deadlines on the very days you were committed to [Westmoreland County Community College] in Latrobe that caused this mess. You did this to yourself. You treated a difficult full time job as a part-time one.” (ECF No. 101-5 at 19 (Craig-Kahan emails).) Kahan, pursuant to his limited grievance rights as a first-year, probationary nontenured faculty member, filed a grievance challenging the non-renewal of his contract. (ECF No. 122, SRU CCSMF ¶¶ fi-fi, 36, 43; ECF No. 80-4 at 4 (Kahan grievance).) Kahan’s grievance was denied on May 11, 2010, because Kahan’s grievance rights were limited, by the CBA, to SRU’s failure to provide timely notice of non-renewal, and Kahan received notice of his nonrenewal before the April 1, 2010 deadline. (ECF No. 122, SRU CCSMF ¶ 35; ECF No. 80-4 at 2 (grievance response).) Kahan acknowledges that he “was in fact tardy turning in [his] midterm grades in both the fall and spring semesters” and characterizes the error as “a serious failure on [his] part” in the rebuttal memorandum he sent to Provost Williams on March 28, 2010. (ECF No. 80-3 at 39-41 (Kahan memo).) Kahan also admits that he did not attend a faculty meeting in January 2010, without giving advance notice to the department chairman of his absence, (ECF No. 122, SRU CCSMF ¶ 9), and submitted his attendance reports, referred to as “salmon-colored sheets,” five days late in February 2010, (id. ¶ 8). Although Kahan acknowledges these deficiencies, he claims that his contract was not renewed because Craig supported the hiring of Daniel Barr, when Kahan was hired in 2009, and because Kahan complained to Craig about Mrs. Winslow bring rude to him and about being pressured to give her son extra time on an assignment and a passing grade in his class. (ECF No. 120, Mr. Winslow CCSMF ¶ 25; ECF No. 122, SRU CCSMF ¶¶ 28-30.) Kahan similarly contends that Dean Tsuquiashi-Daddesio reversed her decision to support renewal of his contract “based on Ms. Winslow’s complaints about Kahan.” (ECF No. 122, SRU CCSMF ¶ 40.) 2. Kahan’s 2011 Application for Employment In 2011, Kahan applied for the faculty position in SRU’s history department that was created when his contract was not renewed in 2010. (ECF No. 122, SRU CCSMF ¶ 56.) Kahan’s position was not filled during the 2010-2011 academic year, and the classes that would have been taught by Kahan that year, were instead taught by a female faculty member. (Id. ¶ 61.) More than 130 applications were received for the open faculty position in 2011 .(Id.) Kahan was not one of the three applicants selected by the search committee for an on-campus interview. (Id. ¶ 57.) SRU hired a male for the position. (Id. ¶ 61; ECF No. 80-4 (William Bergmann offer letter).) Prior to submitting his application, Ka-han filed a charge of gender discrimination and retaliation with the Equal Employment Opportunity Commission (“EEOC”). (Id. ¶ 59.) Kahan’s only evidence that the search committee was aware of Kahan’s EEOC charge is an incongruent citation to Craig’s deposition acknowledging that the head of the search committee notified hi m, at some indeterminate time, that Kahan applied for the vacancy, and an email from Kahan’s former colleague, Aaron Cowan, refusing to allow Kahan to use his recommendation letter to apply for the job at SRU because Cowan was serving on the search committee and because, in Cowan’s personal opinion, if Kahan were hired, there would be continued conflict between Kahan and the administration. (ECF No. 122, SRU CCSMF ¶ 60; ECF No. 101-10 at 35 (Cowan email).) B. Conflicts with Mrs. Winslow According to Kahan, Craig recommended that Kahan’s contract not be renewed in order to placate Mrs. Winslow, with whom Kahan had various personal and professional conflicts, because Craig did not want the history department’s secretary to quit, resulting in an increase to his own workload. (ECF No. 100 (Kahan brief) at 4-5; ECF No. 122, SRU CCSMF ¶¶ 29-30.) Kahan similarly contends that Dean Tsuquiashi-Daddesio did not support renewal of his contract because Mrs. Win-slow complained about him. (ECF No. 122, SRU CCSMF ¶ 40.) There is no dispute on this record that Mrs. Winslow did not want SRU to hire Kahan in 2009, thought Kahan was “weird” when he interviewed on campus at that time, and came to personally dislike Kahan after he was hired. (ECF No. 120, Mr. Winslow CCSMF ¶¶ 74-79; ECF No. 121, Tommy Winslow CCSMF ¶¶ 55-60.) 1. Tommy’s Final Report Tommy Winslow was a student in Ka-han’s 400-level Pennsylvania history class during the fall 2009 semester. (ECF No. 122, SRU CCSMF ¶44.) Tommy Win-slow, who was diagnosed with attention deficit disorder at the age of nine, was registered with SRU’s Office for Students with Disabilities, which intervened in December 2009, after Kahan initially refused to grant Tommy an extension of time for the submission of his final report. (ECF No. 120, Mr. Winslow CCSMF ¶ 46-47; ECF No. 122, SRU CCSMF ¶¶ 45-46; ECF No. 101-11 at 23-24 (Mrs. Winslow depo. at 93-94).) Tommy Winslow was eventually granted an extension and his final grade was reported as an incomplete, pending submission of his final report. (ECF No. 122, SRU CCSMF ¶¶ 45-46.) According to Kahan, at the beginning of the spring 2010 semester, Craig pressured Kahan to give Tommy Winslow a final grade of D, even though Kahan’s and a fellow faculty member’s grading of his final report justified a final grade of F. (IcL ¶¶ 47-49, 98.) Kahan claims that his resistance to doing so resulted in hostility between Kahan and Craig and Kahan and Mrs. Winslow. (Id.) Tommy Winslow told Mrs. Winslow that Kahan initially refused to grant him an extension on his final report in mid-December 2009. (Id. ¶ 83.) Mrs. Winslow contacted Linda Quidone, Director of the Office for Students with Disabilities (“Qui-done”), to secure an extension on behalf of her son. (Id. ¶ 89.) Mrs. Winslow was dissatisfied when an extension of less than a day was offered, at which time Mr. Win-slow became involved by contacting the Office for Students with Disabilities, which referred Mr. Winslow to Holly McCoy, the Assistant Vice President of Diversity and Equal Opportunity (“McCoy”), when he inquired about how he could go about filing a complaint based upon Kahan’s refusal to give Tommy Winslow more time to submit his final report. (ECF No. 101-11 at 34 (Mrs. Winslow depo. at 149); ECF No. 80-3 at 47-48 (Mrs. Winslow complaint letter); ECF No. 120, Mr. Winslow CCSMF ¶¶ 48^19, 57, 59.) After these contacts, Tommy Winslow was granted an extension of approximately one week, with which Mr. and Mrs. Winslow were satisfied. (ECF No. 80-3 at 47-48 (Mrs. Win-slow complaint letter); ECF No. 120, Mr. Winslow CCSMF ¶ 62; ECF No. 122, SRU CCSMF ¶ 97.) Prior to these communications, Tommy Winslow complained to his parents about Kahan’s classroom demeanor, and detailed for them that one day, when Tommy was staring out the window during a class session, Kahan asked him whether he was looking at a good-looking man, and then stated that the comment was not meant to be made in a sexual manner, causing the class to laugh at him. (ECF No. 120, Mr. Winslow CCSMF ¶¶ 98, 100-04; ECF No. 121, Tommy Winslow CCSMF ¶¶ 23, 50, 86, 88.) Mr. and Mrs. Winslow relayed this information to Quidone and McCoy while attempting to secure an extension of time for their son’s final report. (ECF No. 120, Mr. Winslow CCSMF ¶¶24, 39-41, 43.) Mrs. Winslow told Dean Tsuquia-shi-Daddesio about the “good-looking man” comment during a March 19, 2010 meeting regarding Kahan. (ECF No. 120, Mr. Winslow CCSMF ¶ 86; ECF No. 121, Tommy Winslow CCSMF ¶ 86.) Mrs. Winslow also wrote a letter of complaint to Craig, dated March 21, 2010, regarding Kahan’s poor treatment of her son, including specifically Kahan’s failure to initially grant him an extension of time in conformance with the Americans with Disabilities Act, 42 U.S.C. § 12101-12117 (the “ADA”). (ECF No. 80-3 at 47-48 (Mrs. Winslow complaint letter).) Mrs. Winslow’s letter generally accuses Kahan of “harassing]” and “targeting]” Tommy Winslow because of his disability, specifically discusses the steps taken to obtain an extension of time for his final report in December 2009, and references Mrs. and Mr. Winslow’s interest, at that time, in filing a complaint under the ADA, but does not mention the “good-looking man” comment or make any reference to or allegation of sexual harassment. (Id.) According to Kahan, Qui done informed him during a December 2009 telephone call about the extension for Tommy Win-slow that Mr. Winslow threatened to sue Kahan and SRU for sexual harassment based upon the “good-looking man” comment. (ECF No. 120, Mr. Winslow CCSMF ¶¶ 24, 39-41, 43.) Both Quidone and Mr. Winslow dispute this fact and testify in conformity with the other that Mr. Winslow asked only how he could file a complaint based upon Kahan’s refusal to grant Tommy a reasonable accommodation under the ADA. (ECF No. 120, Mr. Win-slow CCSMF ¶¶ 50-51, 53.) This matter will be addressed in section III.A.2(b). 2. The Scantron Sheets Kahan and Craig met on March 15, 2010, the first day that SRU was in session following spring break, to address concerns that Kahan raised with Craig via emails dated March 3, 2010, and March 12, 2010, with respect to Mrs. Winslow’s refusal to order certain testing supplies, called scantron sheets, for Kahan. (ECF No. 80-3 at 43 and 45 (Kahan emails); ECF No. 117-1 at 73 (Craig depo. at 166); ECF No. 122, SRU CCSMF ¶¶ 13, 24-25, 117-18.) During this meeting, Kahan informed Craig that Mrs. Winslow had been rude to him since the dispute concerning the deadline for Tommy Winslow’s final report arose in December 2009. (ECF No. 117-1 at 69 (Craig depo. at 162).) Craig instructed Kahan to order supplies directly from him, instead of Mrs. Winslow, in the future. (ECF No. 117-1 at 69-70, 75-76 (Craig depo. at 162-63,167-69).) After speaking with Kahan about the conflict concerning the scantron sheets, Craig spoke with Mrs. Winslow about the matter. (ECF No. 117-1 at 68-71 (Craig depo. at 161-64).) Mrs. Winslow’s account of the conversation that she had with Ka-han about ordering scantron sheets essentially matched Kahan’s account, with the primary exception being that Mrs. Win-slow claimed that Kahan was the one being rude to her. (Id. at 68-71, 78-80 (Craig depo. at 161-64, 171-73).) Craig also spoke with Dean Tsuquiashi-Daddesio about the matter on March 15, 2010, in order to obtain her approval of his instruction to Kahan that he not approach Mrs. Winslow directly to order supplies for the present time, and to discuss Kahan’s missed deadlines. (Id. at 75 (Craig depo. at 167); ECF No. 122, SRU CCSMF ¶ 125.) 3. The March 21, 2010 Complaint Letter Mrs. Winslow met with Dean Tsuquia-shi-Daddesio on March 19, 2010, at the Dean’s request, to discuss problems that her son Tommy Winslow had with Kahan during the fall 2009 semester. (ECF No. 122, SRU CCSMF ¶ 156.) Mrs. Winslow told the Dean that Kahan targeted, harassed, embarrassed, and humiliated her son during class, and specifically recounted the “good-looking man” comment. (Id. ¶ 157.) Following this meeting, which was on a Friday, Mrs. Winslow drafted a letter, dated Sunday, March 21, 2010, and addressed to Craig, in which she summarized her complaints about how her son, Tommy Winslow, was treated in Kahan’s history class the previous semester. (ECF No. 80-3 at 47-48 (Mrs. Winslow complaint letter); ECF No. 122, SRU CCSMF ¶ 159.) By way of chronological context, Dean Tsuquiashi-Daddesio and Craig discussed Kahan’s failure to submit his mid-term grades in a timely manner on March 15, 2010, at which time Craig informed Dean Tsuquiashi-Daddesio that he no longer supported renewal of Kahan’s contract. (ECF No. 122, SRU CCSMF ¶¶ 13-15, 125.) Craig submitted a draft memorandum to Dean Tsuquiashi-Daddesio about Kahan on March 18, 2010, and a final memorandum to her on March 19, 2010. (ECF No. 101-4 at 46^7 (Craig draft memo); ECF No. 80-3 at 28-29 (Craig final memo).) Dean Tsuquiashi-Daddesio spoke with Provost Williams about Kahan on March 23, 2010, at which time the Dean had begun to draft a memorandum to Provost Williams about Kahan. (ECF No. 101-5 at 2-4 (Dean draft memo).) Craig informed Kahan that he no longer supported renewal of his contract on either March 22 or 23, 2010. (ECF No. 122, SRU CCSMF ¶ 15; ECF No. 105-2 at 45 (Craig memo); ECF No. 109-3 at 39 (Craig email); ECF No. 80-3 at 40 (Kahan memo).) Dean Tsuquiashi-Daddesio informed Kahan that she no longer supported the renewal of his contract on March 25, 2010. (ECF No. 122, SRU CCSMF ¶ 168.) Kahan received notice from President Smith on March 30, 2010, that his one-year probationary teaching contract would not be renewed. (ECF No. 80-3 at 35 (Smith letter); ECF No. 122, SRU CCSMF ¶ 41.) 4. The May 18, 2010 Incident On May 18, 2010, Mrs. Winslow reported an incident to SRU campus police during which Kahan allegedly entered her office, called her a “bitch,” called Tommy Winslow a “retard,” wished them both to “die a painful death,” threw a DVD toward her, and said “now put this away.” (ECF No. 122, SRU CCSMF ¶50; ECF No. 105-3 at 3-4 (Mrs. Winslow’s SRU police voluntary statement form).) When Dean Tsuquiashi-Daddesio’s secretary, Amy McCamey, called Mrs. Winslow’s office shortly after this incident occurred to finalize previously-made lunch plans, Mrs. Winslow relayed the incident to her. (ECF No. 122, SRU CCSMF ¶ 190.) Ms. McCamey spoke with the Dean about the incident and relayed to Mrs. Winslow that the Dean stated that Mrs. Winslow should report the incident to campus police if she felt threatened or unsafe, which she did. (Id. ¶¶ 63, 190.) The SRU police spoke with Kahan and Craig about the incident the following day. (Id. ¶¶ 64; ECF No. 80-5 at 34-35 (SRU incident report form).) Kahan denied making any such statements, and instead claimed that, while he was cleaning out his office, he asked Mrs. Winslow to put a DVD away for him, which was part of her job duties. (ECF No. 80-5 at 35 (SRU incident report form); ECF No. 122, SRU CCSMF ¶¶51, 189.) During his interview, Craig indicated that he felt harassed by Kahan, and gave the SRU police officer a copy of an email from Kahan, dated May 17, 2010, in which Ka-han called Craig a “liar,” a “coward,” “incompetent,” and “petty, vindictive and completely dishonest.” (ECF No. 80-5 at 34-35 (SRU incident report form); ECF No. 80-4 at 12 (Kahan email); ECF No. 122, SRU CCSMF ¶ 64.) Kahan contends that after this incident, he was instructed, by letter, not to return to the SRU campus without prior approval. (ECF No. 122, SRU CCSMF ¶ 201.) Ka-han fails to include this letter, which he labels “Ex. 97” in his response to SRU’s CCSMF ¶201, in his appendix, and the court was unable to locate the document elsewhere in the record. (ECF No. 101 at 2 (appendix table of contents); ECF No. 101 — 4 to-8 (plaintiffs exhibits).) In the summary judgment papers, Kahan contends not that he was required to obtain an escort in order to visit campus, but that he was required to obtain “SRU’s express permission” before returning to campus after the May 18, 2010 incident. (ECF No. 122, SRU’s CCSMF ¶ 201.) Without access to the letter, the court is unable to determine which directive Kahan was given. Notably, defendants deny the averment in Kahan’s second amended complaint that “SRU barred Dr. Kahan from entering onto campus without an escort” after the May 18, 2010 incident. (ECF Nos. 53, 54, and 64¶70.) The SRU campus police filed a criminal complaint for harassment against Kahan at the office of Magistrate Shaffer in Slippery Rock, Pennsylvania on May 20, 2010. (ECF No. 122, SRU CCSMF ¶ 64.) A preliminary hearing was held on the charge on September 14, 2010, at which time the presiding judge noted an administrative error in the paperwork, not caused by any SRU Defendant, and held the matter over for further instructions. (Id. ¶¶54, 65-67.) SRU police refiled the charge in October 2010, to remedy the error, but the Butler County District Attorney later advised the charging officer that the case would not be pursued. (Id. ¶¶ 55, 68.) II. SUMMARY JUDGMENT STANDARD Summary judgment is appropriate if the record shows that there is no genuine dispute with respect to any material fact and the movant is entitled to judgment as a matter of law. Fed. R. Crv. P. 56(a). The mere existence of a factual dispute, however, will not necessarily defeat a motion for summary judgment. Only a dispute over a material fact — that is, a fact that would affect the outcome of the suit under the governing substantive law — will preclude the entry of summary judgment. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). Even then, the dispute over the material fact must be genuine, such that a reasonable jury could resolve it in the nonmoving party’s favor. Id. at 248-49, 106 S.Ct. 2505. In deciding a summary judgment motion, a court must view the facts in the light most favorable to the nonmoving party and must draw all reasonable inferences, and resolve all doubts, in favor of the nonmoving party. Liberty Lobby, 477 U.S. at 255, 106 S.Ct. 2505; Wishkin v. Potter, 476 F.3d 180, 184 (3d Cir.2007); Woodside v. Sch. Dist. of Phila. Bd. of Educ., 248 F.3d 129, 130 (3d Cir.2001); Doe v. Cnty. of Centre, PA, 242 F.3d 437, 446 (3d Cir.2001); Heller v. Shaw Indus., Inc., 167 F.3d 146, 151 (3d Cir.1999). A court must not engage in credibility determinations at the summary judgment stage. Simpson v. Kay Jewelers, Div. of Sterling, Inc., 142 F.3d 639, 643 n. 3 (3d Cir.1998). One of the principal purposes of summary judgment is to isolate and dispose of factually unsupported claims or defenses. Celotex Corp. v. Catrett, 477 U.S. 317, 323-24, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). The summary judgment inquiry asks whether there is a need for trial — “whether, in other words, there are any genuine factual issues that properly can be resolved only by a finder of fact because they may reasonably be resolved in favor of either party.” Liberty Lobby, 477 U.S. at 250, 106 S.Ct. 2505. In ruling on a motion for summary judgment, the court’s function is not to weigh the evidence or to determine the truth of the matter, but only to determine whether the evidence of record is such that a reasonable jury could return a verdict for the nonmoving party. Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150-51, 120 S.Ct. 2097, 147 L.Ed.2d 105 (2000) (citing decisions); Liberty Lobby, 477 U.S. at 248-49, 106 S.Ct. 2505. The burden of showing that no genuine issue of material fact exists rests initially on the party moving for summary judgment. Celotex, 477 U.S. at 323, 106 S.Ct. 2548; Aman v. Cort Furniture Rental Corp., 85 F.3d 1074, 1080 (3d Cir.1996). The moving party may satisfy its burden either by producing evidence showing the absence of a genuine issue of material fact or by demonstrating that there is an absence of evidence to support the nonmoving party’s case. Marten v. Godwin, 499 F.3d 290, 295 (3d Cir.2007) (citing Celotex, 477 U.S. at 325, 106 S.Ct. 2548). A defendant who moves for summary judgment is not required to refute every essential element of the plaintiffs claim; rather, the defendant must only point out the absence or insufficiency of plaintiffs evidence offered in support of one or more those elements. Celotex, 477 U.S. at 322-23, 106 S.Ct. 2548. Once the movant meets that burden, the burden shifts to the nonmoving party to “set forth specific facts showing that there is a genuine issue for trial” and to present sufficient evidence demonstrating that there is indeed a genuine and material factual dispute for a jury to decide. Fed. R. Civ. P. 56(e); see Liberty Lobby, 477 U.S. at 247-48, 106 S.Ct. 2505; Celotex, 477 U.S. at 323-25, 106 S.Ct. 2548. If the evidence the nonmovant produces is “merely colorable, or is not significantly probative,” the moving party is entitled to judgment as a matter of law. Liberty Lobby, 477 U.S. at 249, 106 S.Ct. 2505. The nonmoving party must “do more than simply show that there is some metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). To survive summary judgment, the nonmoving party must “make a showing sufficient to establish the existence of [every] element essential to that party’s case, and on which that party will bear the burden of proof at trial.” Celotex, 477 U.S. at 322, 106 S.Ct. 2548. Furthermore, “[w]hen opposing summary judgment, the non-movant may not rest upon mere allegations, but rather must ‘identify those facts of record which would contradict the facts identified by the movant.’ ” Corliss v. Varner, 247 Fed.Appx. 353, 354 (3d Cir.2007) (quoting Port Auth. of N.Y. and N.J. v. Affiliated FM Ins. Co., 311 F.3d 226, 233 (3d Cir.2002)). III. DISCUSSION A. The Employment Claims In his second amended complaint, Ka-han asserts four claims under Title VII and two claims under Title IX. Kahan alleges that the SRU Defendants engaged in gender discrimination and created a gender-based hostile work environment, in violation of both Title VII and Title IX. (ECF No. 53 at Counts I-IV.) Kahan additionally accuses the SRU Defendants of violating Title VII by retaliating against him. (Id. at Counts XVI-XVII.) As an initial matter, although the parties provided the court with copies of the charge of discrimination that Kahan filed with the EEOC, (ECF No. 80-4 at 6-10), the court was unable to locate a right-to-sue letter in the record. The receipt of the right-to-sue letter indicates that a complainant has exhausted administrative remedies, which is an essential element for bringing a claim in court under Title VII. Burgh v. Borough Council of Borough of Montrose, 251 F.3d 465, 470 (3d Cir.2001); see Stampone v. Freeman Decorating Co., 196 Fed.Appx. 123, 126 (3d Cir.2006) (“In the absence of a right-to-sue letter, a Title VII suit can be dismissed for failure to state a claim upon which relief may be granted.”). In his second amended complaint, Kahan alleges that he received a right-to-sue letter from the “Civil Rights Division of the U.S. Department of Justice” on or about January 3, 2012, but the letter is not attached to that pleading either. (ECF No. 53 ¶ 16.) Mr. Winslow and Tommy Winslow deny Kahan’s allegation about the right-to-sue letter based upon a lack of knowledge, (ECF No. 64 ¶ 16), and the SRU Defendants respond that the “document speaks for itself,” (ECF No. 54 ¶ 16.) No defendant challenges Kahan’s Title VII claims on this jurisdictional basis in its summary judgment papers, and, therefore, the court will accept as true, for the purpose of deciding the instant motion, Kahan’s averment that he properly administratively exhausted his claims before proceeding in federal court: 1. Gender Discrimination Claims (Counts I and III) SRU moves for summary judgment on Kahan’s gender discrimination claims on the ground that Kahan cannot establish a prima facie ease, and that even if he could, he is unable to prove that SRU’s reasons for not renewing his one-year contract were a pretext for gender discrimination. (ECF No. 78 (SRU brief) at 11-12.) In response, Kahan alleges that SRU engaged in gender discrimination, in violation of both Title VII and Title IX, by not renewing his contract after one year, and by filing criminal charges against him based upon the “gender stereotype of the aggressive and hostile male” and “hyper-masculine rage-based language.” (ECF No. 100 (Kahan brief) at 14-15.) For the reasons set forth below, none of Kahan’s Title VII or Title IX gender discrimination claims survives summary judgment. As an initial matter, it remains an open issue in this jurisdiction, and there is a split of authority elsewhere, with respect to whether a public employee can bring a cumulative Title IX gender discrimination claim based upon the same conduct that supports a Title VII gender discrimination claim. Torres v. Sch. Dist. of Manatee Cnty., Fla., 14-1021, 2014 WL 4185364, at *5-6 (M.D.Fl. Aug. 22, 2014) (collecting decisions). This court need not answer this question, however, because there is no dispute that, if duplicate claims can be pursued, the same analytical framework applies to gender discrimination claims brought pursuant to either statute. Tingley-Kelley v. Trustees of Univ. of Pa., 677 F.Supp.2d 764, 775 (E.D.Pa.2010) (citing decisions). A distinction typically arises between these claims only when a plaintiff has failed to exhaust his or her administrative remedies, as required by Title VII, but not by Title IX, prior to filing suit. As discussed above, however, this court is presuming for the purpose of deciding the instant motion that Kahan received a right-to-sue letter, and can pursue a Title VII claim in federal court. See supra III.A. In this case, therefore, there is no relevant distinction between Kahan’s Title VII and Title IX gender discrimination claims, and they will be considered together, with no further distinction made in this opinion. Although neither party acknowledges this principle, because Kahan is a male, his claim is one for “reverse discrimination.” All that is required to establish a prima facie case in such circumstances is evidence permitting a fact finder to conclude that the employer is treating some people less favorably than other people, based upon gender. Iadimarco v. Runyon, 190 F.3d 151, 161 (3d Cir.1999); see Besko v. New Jersey Juvenile Justice Comm’n, 558 Fed.Appx. 295, 298 (3d Cir.2014) (applying Iadimarco and finding that all that is required to establish a prima facie ease of reverse discrimination is a sufficient showing that the employer is treating some people less favorably than others based upon a trait that is protected under Title VII.) Once this showing is made, the employer must proffer a legitimate, nondiscriminatory reason for the employment action. Iadimarco, 190 F.3d at 157-58 (citing McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973)); see Goosby, 228 F.3d at 319. In order to defeat summary judgment the employee must then point to some evidence, direct or circumstantial, from which a fact-finder could reasonably either: (1) disbelieve the employer’s articulated legitimate reasons; or (2) believe that an invidious discriminatory reason was more likely than not a motivating cause of the employer’s action. Iadimarco, 190 F.3d at 157-58; Fuentes v. Perskie, 32 F.3d 759, 764 (3d Cir.1994). Put another way, to avoid summary judgment, the employee’s evidence must allow a fact-finder to reasonably infer that the employer’s proffered nondiscriminatory reason was either a post hoc fabrication, or otherwise did not actually motivate the employment action. Doe v. C.A.R.S. Protection Plus, Inc., 527 F.3d 358, 370 (3d Cir.2008). a. Adverse Employment Action Before proceeding, the court must address Kahan’s eonclusory allegations that both the non-renewal of his contract, and Mrs. Winslow’s report to the SRU campus police about the May 18, 2010 incident, were gender-based adverse employment actions. An adverse employment action requires “a significant change in employment status, such as hiring, firing, failing to promote, reassignment with significantly different responsibilities, or a decision causing a significant change in benefits.” Burlington Indus., Inc. v. Ellerth, 524 U.S. 742, 761, 118 S.Ct. 2257, 141 L.Ed.2d 633 (1998). There can be no reasonable dispute that the non-renewal of Kahan’s one-year, probationary contract qualifies as an adverse employment action. Kahan’s brief is silent, however, with respect to how Mrs. Winslow’s report about the May 18, 2010 incident, and the resulting criminal charges themselves, caused a “significant change in employment status, responsibilities, or benefits.” Burlington, 524 U.S. at 761, 118 S.Ct. 2257. While there can be no reasonable dispute that being accused of and criminally charged with assault is an adverse event, Kahan has not explained how that event resulted in an adverse employment action. At the time of the May 18, 2010 incident, Kahan had already received notice that his contract would not be renewed. The court’s independent review of the record indicates that the only possible connection between Mrs. Winslow’s report about the May 18, 2010 incident and the terms and conditions of Kahan’s employment is Kahan’s assertion that he was not permitted to be on the SRU campus without permission or an escort because of the incident. (ECF No. 122, SRU CCSMF ¶ 201 (prior permission required); ECF No. 53 ¶ 70 (escort required).) As set forth in section I.B.4., the letter purportedly notifying Kahan about these conditions is not attached to Kahan’s summary judgment papers, and defendants deny the averment in Kahan’s second amended complaint that such conditions were placed on Kahan after the incident. (ECF No. 101 at 2 (appendix table of contents); ECF No. 101-4 to -8 (plaintiffs exhibits); ECF Nos. 53, 54, and 64 ¶ 70.) Although there is no evidentiary support for Kahan’s assertion, the court will accept it as true only for the purpose of deciding the instant motion. Even accepting Kahan’s allegation as true, it would not support a reasonable jury finding that Kahan suffered an adverse employment action as a result of Mrs. Winslow’s May 18, 2010 report to the SRU campus police. By Kahan’s own recitation of the content of the letter, he was permitted to visit campus provided that certain conditions were met. (ECF No. 122, SRU CCSMF ¶ 201 (prior permission required); ECF No. 53 ¶ 70 (escort required).) Kahan submits no evidence, and fails to even allege, that he wanted, or needed, to return to campus after May 18, 2010, but was prevented from doing so because of either alleged directive. Kahan submits no evidence to establish that the classes he taught in the spring 2010 semester were still in session, or that he had other professional responsibilities that could only be fulfilled by visiting campus. The record is devoid of any indication that Kahan was unable to do his job because he was required to either seek prior approval to be on campus, or to obtain an escort, or both. Based upon these facts, no reasonable jury could conclude that the directive that Kahan not return to the SRU campus without prior permission or an escort was a significant change in employment status, responsibilities, or benefits, thus qualifying it as an adverse employment action. Because, however, the non-renewal of Kahan’s contract does qualify as an adverse employment action, and because Ka-han’s employment discrimination claims cannot survive summary judgment on the alternative grounds discussed below, Ka-han’s failure to establish that Mrs. Win-slow’s report to the SRU campus police about the May 18, 2010 incident was a gender-based adverse employment action is ultimately inconsequential. The deficiency, therefore, will not be discussed further in this opinion. b. The Prima Facie Case According to Kahan, he can establish a prima facie case of gender discrimination because he was the “target of gender stereotyping as the overly masculine alpha male in a reserved academic setting.” (ECF No. 100 (Kahan brief) at 12.) Kahan notes that a female faculty member, Rhea Klenovich (“Klenovich”), was treated more favorably than he was because she did not have to share her office, as did Kahan, and she taught the classes that Kahan planned to teach during the 2010-2011 academic year. (Id. at 15; ECF No. 122, SRU CCSMF ¶ 212.) The court considers Kahan’s contentions in reverse order, but concludes that neither satisfies Kahan’s burden to prove that SRU treated males less favorably than females. Iadi-marco, 190 F.3d at 161. (i) Comparator — Klenovich The comparison to Klenovich cannot satisfy Kahan’s burden to prove a prima facie case of gender discrimination. As an initial matter, Kahan failed to produce evidence indicating whether Klenovich was a probationary faculty member, or if she was, in which year of her probationary term she was during the 2009-2010 academic year. The record is devoid of any evidence about what Klenovich’s job title or duties were, to whom she reported, or her seniority at SRU. The entirety of Ka-han’s evidence with respect to Klenovich is a single statement, in his own declaration, that Klenovich was a “lower ranked female faculty member.” (ECF No. 122, SRU CCSMF ¶ 212.) Without further information, or corroboration, which would have been readily available in discovery, the court cannot assess whether Klenovich was a similarly situated employee to Kahan. (ECF No. 101-13 (Kahan deck) at 3-4); Wilcher v. Postmaster General, 441 Fed. Appx. 879, 882 (3d Cir.2011); Doe v. C.A.R.S. Prot. Plus, Inc., 527 F.3d 358, 366 (3d Cir.2008); Mun. Revenue Services, Inc. v. McBlain, 347 Fed.Appx. 817, 825 (3d Cir.2009) (finding that comparators must be alike, but not identical, in all relevant respects); Borrell v. Bloomsburg Univ., 955 F.Supp.2d 390, 405 (M.D.Pa.2013) (similar). The record is likewise devoid of any evidence that would permit the court to evaluate whether the circumstances under which Kahan was assigned an office at SRU indicate discriminatory treatment on the basis of gender. The isolated and conclusory fact that Kahan was required to share an office, but Klenovich was not, does not indicate a gender bias. In fact, by Kahan’s own account, no other faculty member, male or female, was required to share an office other than Kahan, indicating that SRU assigned faculty offices based upon variables other than gender. (ECF No. 122, SRU CCSMF ¶212.) According to Kahan’s own factual averments, no reasonable jury could infer that SRU treated females more favorably than males based upon how faculty officers were assigned, or that Kahan received a less favorable office assignment because he is male. Likewise, the fact that Klenovich taught the classes that Kahan was scheduled to teach during the 2010-2011 academic year gives rise .to no inference of gender bias. (Id. ¶ 61.) This female faculty member was not hired to fill the teaching vacancy created when Kahan’s contract was not renewed; instead, a male was hired into that position. (Id.) Klenovich was only tasked with teaching Kahan’s classes during the 2010-2011 academic year, until a new professor could be hired for the 2011-2012 academic year. (Id.) As noted above, although Kahan asserts that Klenovich was “less qualified with a lower degree,” he fails to submit any evidence to support that bare allegation. (ECF No. 100 (Ka-han brief) at 15.) This evidentiary deficiency is without consequence, however, because Kahan fails to explain how, even if this fact were true, a less-qualified female teaching the classes he was scheduled to teach in the 2010-2011 academic year raises an inference of gender discrimination under the facts of this case. Kahan has not established that these unspecified “qualifications” were the only, or even the most important, factor SRU considered when assigning classes. The record includes no evidence about Klenovich’s areas of expertise, existing course-load for the 2010-2011 academic year, class schedule, or personal availability, as compared to male faculty members. The record, therefore, contains no evidence from which a reasonable jury could make the logical leap that Kahan was the victim of reverse gender discrimination based solely upon his conclusory allegation that the classes he planned to teach in the 2010-2011 academic year were assigned to a woman. Solomon v. Soc’y of Auto. Engineers, 41 Fed.Appx. 585, 586 (3d Cir.2002). Neither comparison asserted by Kahan to this female faculty member would permit a reasonable jury to make an inference of gender discrimination. (ii) Gender Stereotypes Kahan’s multiple references to supposed gender stereotypes, likewise, do not give rise to an inference of gender discrimination, as Kahan alleges. According to Kahan’s opposition brief, he can establish a prima facie case because Mrs. Winslow complained about Kahan’s “harassment and targeting of’ her son due to his disability, and about Kahan’s “good-looking man” comment, and described or portrayed Kahan as “sneaky,” a liar, “arrogant,” “rude,” “demanding,” “self-centered,” “aggressive,” “violent,” and “belittling,” among other things, all of which “conform to sexist stereotypes about the alpha male.” (ECF No. 100 (Kahan brief) at 12-14.) Kahan argues that “Craig piggybacked on and adopted these gender stereotypes,” by listing “problematic behavior,” “lack of responsibility,” “arrogance,” and “other personality issues” in his March 18, 2010 draft memorandum to Dean Tsuquiashi-Dadde-sio explaining why he was rescinding his prior recommendation that Kahan’s contract be renewed (Id. at 14.) None of the comments to which Kahan cites, whether made by Mrs. Winslow or Craig, are inherently gender-specific. In order to rule in Kahan’s favor, a jury would be required to conclude that men, but not women, are “rude,” “demanding,” “aggressive,” “irresponsible,” or “belittling,” and that only male teachers target or harass students about their disabilities or make “odd” remarks to students when they are inattentive during class. There is no basis on this record for a reasonable jury to make that finding. Kahan produced no evidence that would support such a finding in this case, beyond his own personal belief and attorney argument. A review of the decisions upon which Kahan relies to support his argument that he was the victim of invidious gender stereotypes at SRU actually demonstrates the deficiencies in Kahan’s prima facie case. In Tingley-Kelley, a student who was repeatedly denied admission to an academic program brought forth evidence that admission committee members denied her application because, as the mother of several young children, she would prioritize her at-home commitments above school. Tingley-Kelley, 677 F.Supp.2d at 775. In Sassaman, the plaintiffs supervisor openly commented that the plaintiff likely engaged in the accused conduct because men have a propensity to sexually harass female co-workers. Sassaman v. Gamache, 566 F.3d 307, 312-13 (2d Cir.2009). Comments about females’ failure to prioritize work over family commitments, or about males’ propensity to sexually harass female coworkers are substantively and dis-positively dissimilar to Kahan’s evidence that Mrs. Winslow and Craig described him as “rude” or “arrogant” or “self-centered.” The latter terms do not have any inherent gender-specific meaning, and ascribe no pejorative characteristic to Kahan based upon an invidious gender stereotype. No reasonable jury could infer that SRU treated females more favorably than males based upon the evidence of purported gender stereotypes produced by Kahan, making it impossible for Kahan to satisfy his burden to establish a prima facie case of gender discrimination on this basis. Iadi-marco, 190 F.3d at 161. Kahan offers no other evidence in support óf his prima facie case. The court concludes, based upon this record, that Kahan did not satisfy his threshold burden of proof on his gender discrimination claims. Judgment could be entered against Kahan on his Title VII and Title IX gender discrimination claims on this basis alone. For the purpose of completeness, however, the court will consider whether Kahan would be able to prove that SRU’s proffered legitimate, nondiscriminatory reason for not renewing his contract was a pretext for discrimination. Because Kahan is unable to meet his burden to prove pretext, entry of judgment in favor of SRU on Counts I and III remains proper under that circumstance as well, c. Pretext Assuming for the purpose of this opinion only that Kahan could establish a prima facie case of gender discrimination, SRU offered a legitimate, nondiscriminatory reason for not renewing his contract; that Kahan repeatedly missed deadlines and meetings during his first-year, probationary term of employment. (ECF No. 78 (SRU brief) at 11.) Kahan contends that there is ample evidence that SRU’s reason for not renewing his contract is entirely false, largely false, pretextual, or reflects “only de minimus infractions that had been previously excused or condoned in the Department.” (ECF No. 100 (Kahan brief) at 16.) The court analyzes Kahan’s contention under the two-prong Fuentes test. Prong one of the Fuentes test focuses on whether Kahan submits evidence from which a fact-finder could reasonably disbelieve SRU’s articulated legitimate reason for its employment decision. Under this prong, Kahan must point to “such weaknesses, implausibilities, inconsistencies, incoherencies, or contradictions in the employer’s proffered legitimate reasons for its action that a reasonable fact-' finder could rationally find them ‘unworthy of credence,’ ... and hence infer ‘that the employer did not act for [the asserted] nondiscriminatory reasons.’ ” Fuentes, 32 F.3d at 765 (internal citations omitted). The question at prong one of the Fuentes test “is not whether the employer made the best, or even a sound, business decision;” it is whether the real reason for the employment decision was discrimination. Keller v. Orix Credit Alliance, Inc., 130 F.3d 1101, 1109 (3d Cir.1997). Kahan can survive summary judgment under prong two of the Fuentes test if he can demonstrate, through evidence of record, that gender discrimination was more likely than not a motivating cause of the adverse employment action. Fuentes, 32 F.3d at 762. The kinds of evidence relied upon by the Court of Appeals for the Third Circuit under this prong of the Fuentes test are: 1) whether the employer previously discriminated against the plaintiff; 2) whether the employer has discriminated against other persons within the plaintiffs protected class or within another protected class; and 3) whether the employer has previously treated more favorably similarly situated persons not within the protected class. Simpson, 142 F.3d at 644-45. Before proceeding with a detailed analysis of each of these prongs, the court notes that Kahan’s evidence of pretext suffers from a fundamental, oft-repeated, and fatal defect. By Kahan’s own argument, admission, and evidence, even if SRU was attempting to disguise its purported “real reasons” for deciding not to renew his contract, those “real reasons” were that a) Mrs. Winslow was angry and vengeful about how Tommy Winslow was treated by Kahan when Tommy requested an ADA accommodation in December 2009, and SRU chose to placate Mrs. Winslow by not retaining Kahan, and b) Craig was angry that Kahan missed deadlines because he was teaching classes at a local community college at the same time that he taught classes at SRU. (ECF No. 100 (Kahan brief) at 16-17; ECF No. 122, SRU CCSMF ¶ 27.) These “real reasons” are not gender-based, and therefore, are immaterial to a pretext analysis, which is always aimed at determining whether the real reason for the employment decision was discrimination. As discussed in detail above, Kahan’s attempt to infect SRU’s non-renewal decision with gender discrimination based upon Mrs. Winslow’s comments that allegedly characterized Kahan as “the stereotypical alphamale” fails. Although there is no reasonable dispute on this record that Mrs. Winslow did not care for Kahan, there is a complete lack of evidence that Mrs. Winslow’s dislike for Kahan was based upon his gender. Even if Dean Tsuquiashi-Daddesio and Craig changed their renewal recommendation based upon Mrs. Winslow’s complaints about Kahan, it does not follow, from a logical or evidentia-ry standpoint, that Kahan’s contract was not renewed because he is a man, which is always the determinative question in a gender discrimination case. No reasonable jury could conclude, based upon this record and Kahan’s own arguments, that the real reason Kahan’s contract was not renewed was gender discrimination. This fundamental defect makes it impossible for Kahan to satisfy either the first or second prong of the Fuentes test. The court' will non