Full opinion text
ENTRY DISCUSSING PARTIAL GRANT OF SUMMARY JUDGMENT BARKER, Chief Judge. Plaintiffs, Kimberly Van Jelgerhuis (‘Van Jelgerhuis”), Janice Brooks (“Brooks”) and Kathy Page-Nowlin (“Nowlin”) have sued Defendants, Mercury Finance Company of Indiana, Inc. (“Mercury”) and their former supervisor, Jim Johnson (“Johnson”), for sexual harassment in the form of disparate impact, disparate treatment and hostile work environment claims, as well as for invasion of privacy and intentional infliction of emotional distress. Defendants have moved for summary judgment. For the reasons discussed below, this motion is granted in part and denied in part. I. STATEMENT OF FACTS Plaintiffs worked in the Southside Branch of Mercury, an installment contracts purchasing corporation, where Johnson was the regional supervisor. It is undisputed that at all times during plaintiffs’ employment, Mercury had a published policy against sexual harassment. That policy states: It is the policy of the Company that sexual harassment of employees in the workplace is unacceptable and will not be tolerated. Appropriate management and supervisory personnel shall take prompt, corrective action when they become aware of sexual harassment. Any employee who feels that they have been the victim of sexual harassment should notify their supervisor or the Director of Human Resources. All such matters will be handled on a strictly confidential basis. Defendants’ Ex. F. In addition, on May 31, 1994, a memorandum was issued to all Mercury employees stating: In an effort to foster an honorable work environment [at Mercury], we want to offer employees every opportunity to voice their concerns and/or questions regarding moral, ethical or legal business issues. As a result, we have created the MFC EMPLOYEE HOTLINE which is a 24 hour toll-free phone number that enables employees to confidentially and anonymously, if desired, address any questionable activities that may occur in the branches ... [T]he MFC Employee Hotline provides an alternative in instances where employees prefer to voice their concerns outside normal management channels. By ensuring that all business activities are in compliance with our policies and the law, we are able to maintain an environment of integrity and respect. We hope that this confidential “1-800” number will free all employees from worrying about any issues that may affect their professionalism, business/peer relationships or application of policy. Plaintiffs’ Ex. G (emphasis in original). The memorandum was signed by the President of Mercury. Id. The picture of the work environment at Mercury’s Southside branch as painted by the plaintiffs is hardly a pleasant one. Johnson allegedly mistreated a number of the staff there, men as well as women. However, all three plaintiffs allege that Johnson specifically harassed them on the basis of their sex. Van Jelgerhuis’ Claims: According to Van Jelgerhuis, around February 9,1993: Jim Johnson stated that in his dream, we had made a bet that if I lost weight, he would ‘eat me out.’ He said that in his dream, I had come into the office and was wearing a short skirt with no underwear and jumped up on his desk and said ‘O.K. I win, now eat me out.’ Plaintiffs’ Ex. B at 3(a); Van Jelgerhuis Dep. at 252-58. A few months later, Johnson described another dream to Van Jelgerhuis, after first thanking her for “last night”: I ... asked him what he was talking about. He then said that he had a dream about me and in his dream, I was sitting at my desk without a shirt or bra. He said that in his dream, he came in and started sucking on my right breast and said ‘Boy, was it sweet.’ After he said this, I became embarrassed and started to walk away from him and out of his office when he said, “Who are you going to tell? my wife? your husband?’ Plaintiffs’ Ex. B at 3(a); Van Jelgerhuis Dep. at 263-65. In addition to his dream reports to Van Jelgerhuis, Johnson often made comments about Van Jelgerhuis’ physical appearance making numerous references to her “fat ass” and the size of her breasts. Plaintiffs’ Ex. B at 3(a); Van Jelgerhuis Dep. at 149. Johnson allegedly inquired why her husband would stay with her, given that Van Jelgerhuis was, supposedly, so fat. Plaintiffs’ Ex. B at 3(a). In addition, Johnson would comment on Van Jelgerhuis’ clothes and demean- or, and, on at least one occasion, Johnson allegedly implied that Van Jelgerhuis looked like a “hooker working at a truck stop.” Van Jelgerhuis Dep. at 271. Van Jelgerhuis also saw Johnson make sexually harassing comments about other women in the office as well during her employment there. See, e.g., Van Jelgerhuis Dep. at 216 (“I’ve seen Jim Johnson stand in his office and holler about the girl’s chest in the front of the office.”). And, she maintains that there were additional incidents of harassment by Johnson. Van Jelgerhuis at 277 (“Oh, I’m sure that there’s lots more than we haven’t even begin [sic] to get into.”). As a result of Johnson’s harassment, Van Jelgerhuis testified that she had to be prescribed antidepressant drugs to alleviate a nervous condition. Van Jelgerhuis Dep. at 285. According to Van Jelgerhuis, she informed Larry Maride, Johnson’s counterpart at Mercury’s Anderson Branch, of the February 1993 Johnson dream incident. Van Jelgerhuis Dep. at 153. Van Jelgerhuis maintains that on two different occasions she also spoke about the problems with Johnson with Joe Carson. Van Jelgerhuis Dep. at 151-52,164. Carson, a subordinate of Johnson’s at the Southside Branch, was the Branch Operations Manager as well as Van Jelgerhuis’ direct supervisor. Van Jelgerhuis at 162. Van Jelgerhuis also maintains that she attached an anonymous letter to a Mercury workplace survey distributed by Mercury’s president, John Brineat. Van Jelgerhuis Dep. at 144. Although the letter identified neither Van Jelgerhuis nor her branch, it apparently described in fairly specific terms the work environment its author endured. Van Jelgerhuis Dep. at 148-50 (describing letter’s contents as including accounts of Johnson’s behavior in the office as well as recommendation that “someone investigate the office” because the work environment was insufferable). Van Jelgerhuis maintains that the letter was three-pages long. Van Jelgerhuis at 150. The only response that Van Jelgerhuis ever received from Mercury regarding her complaints came from Joe Carson: What do you want me to do[?] If I say it to him [Johnson], he’s going to ride you harder____ If I don’t say anything you’re going to be upset____ What do you expect me to do about it? Van Jelgerhuis Dep. at 152. Van Jelgerhuis allegedly replied to Carson: “I don’t know what you’re supposed to do about it, Mr. Carson, but we shouldn’t have to go through this day in and day out.” Id. Although Van Jelgerhuis did report Johnson’s harassment on these occasions, she concedes that she never contacted Dan Smith, the Mercury employee designated to receive complaints of sexual harassment. Van Jelgerhuis Dep. at 299-301. This was the ease notwithstanding that Smith actually telephoned her on one occasion about the alleged sexual harassment of another Mercury employee. Van Jelgerhuis Dep. at 301. Van Jelgerhuis maintains that she did not report Johnson to Smith because she was afraid of losing her job. Id. She also maintains that as part of his campaign of harassment, Johnson would manipulate her by lessening his harassment if he sensed that she was going to report him. Van Jeigerhuis Dep. at 153, 299-300. When Van Jelgerhuis finally confronted Johnson directly, Johnson told her that her “services were no longer needed.” Van Jelgerhuis Dep. at 173. At that point, when she asked for permission to contact Smith, Johnson told her it was “too late.” Id. Brooks’ Claims: Brooks contends that Johnson sexually harassed her as well during her employment at the Mercury Southside Branch. Brooks was employed at the Southside Branch as a cashier, starting in October 1990; however, a year and a half prior to her leaving, Brooks was relocated to a work station approximately twenty feet from Johnson’s office. She maintains that at that point Johnson’s harassment of her became more “frequent.” Brooks Dep. at 68. During this time,.according to Brooks, Johnson referred to her as “fat” and “ugly” on innumerable occasions, Brooks Dep. at 114 (“I couldn’t count the number of times”), and on more than ten occasions, he remarked on her “fat ass” as she bent over at a file cabinet. Brooks Dep. at 98-100. At least once a month, he allegedly commented on the fact that Brooks was not married to her live-in companion, focusing on the “sex part of it ... eight or nine times.” Brooks Dep. at 115-16. I could just walk in [Johnson’s] office and he could say something to the extent that you’re so fat, I just don’t see how anybody could sleep with you, I don’t see how [your boyfriend] can make love to you, how you can do anything, how you can keep him satisfied____ Brooks’ Dep. at 117. Johnson also allegedly commented about once a month on the size of Brooks’ breasts during that same year and a half period, stating that Brooks’ “boobs were two different sizes.” Brooks Dep at 100, 104. He also, on separate occasions, commented on Brooks’ bras. Brooks Dep. at 103. Brooks maintains that there were other, additional incidents of harassment involving Johnson. Brooks Dep. at 107. It is undisputed that Brooks was aware of Mercury’s policy prohibiting sexual harassment. Brooks Dep. at 61-62. The employee hotline, however, was established after she left Mercury’s employ. It is also undisputed that Brooks never pursued the company’s avenues for reporting the harassment, because, as she put it, she “knew better” than to complain about Johnson, Brooks Dep. at 104, and because she believed she would lose her job if she complained about him. Brooks Dep. at 61. Brooks left Mercury on or about May 16, 1994. Brooks Dep. 52, 57. Her letter to the Indiana Department of Employment states that she applied for and was denied a transfer to another Mercury branch. Plaintiffs’ Ex. C. Nowlin’s Claims: Nowlin initially worked at Mercury’s Southside Branch from early 1992 until August 1993, when she left, in part, due to “some hostility” at the Southside Branch. Nowlin Dep. at 12, 45, 52. However, in May 1994, when her work began to conflict with her son’s school schedule, she returned to work at Mercury. Nowlin Dep. at 47-48. According to Nowlin, during her few months of renewed work at Mercury, Johnson would make statements to her, such as “I’m a lonely old man ..., why don’t you give me a hug?” Nowlin Dep. at 57. On at least one occasion, she obliged him with a hug, an experience she describes as “very humiliating,” although she stated there was nothing sexual about the embrace. Nowlin Dep. at 59, 77. On another occasion, Johnson allegedly asked her for a backrub. Again, she obliged, although it made her “uncomfortable.” Nowlin Dep. at 75-76. On “more than one occasion” Johnson would ask Nowlin to “rub up against him.” Nowlin Dep. at 78-79. Nowlin maintains that she often heard Johnson comment on Brooks’ dress and appearance. Nowlin Dep. at 68-69. Although she acknowledges that she heard Johnson refer to himself as fat, Nowlin Dep. at 70, she never saw him hug anyone else in the office, not even his daughter, who also was employed at the branch. Nowlin, at 59. Nowlin could not remember any additional specific incidents. However, she stated that she was “sure there were other comments,” Nowlin Dep. at 71-72, 73 and that she was certain there “was more.” Nowlin Dep. at 79. Nowlin concedes that she also knew of Mercury’s harassment policy, yet she never pursued any avenue to report Johnson’s behavior. Nowlin Dep. at 45-46. Her letter of resignation stated that she was leaving Mercury’s employ because of the “hostile work environment” at the Southside Branch. Plaintiffs’ Ex. C; Nowlin Dep. at 17. Nowlin resigned from Mercury in July 1994. II. LEGAL STANDARDS/ANALYSIS A. Standard for Summary Judgment Summary judgment is appropriate “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” Fed.R.Civ.Pro. 56(c). A genuine issue of material fact exists if there is sufficient evidence for a jury to return a verdict in favor of the non-moving party on the particular issue. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 2510, 91 L.Ed.2d 202 (1986); Methodist Med'l Ctr. v. American Med'l Sec., Inc., 38 F.3d 316, 319 (7th Cir.1994). On a motion for summary judgment, the burden rests squarely on the moving party to demonstrate “that there is an absence of evidence to support the nonmoving party’s case.” Celotex Corp. v. Catrett, 477 U.S. 317, 325, 106 S.Ct. 2548, 2554, 91 L.Ed.2d 265 (1986). However, after the moving party has demonstrated the absence of a genuine issue for trial, the responsibility shifts to the nonmovants to “go beyond the pleadings” and point to evidence of a genuine factual dispute precluding summary judgment. Celotex Corp., 477 U.S. at 322-23, 106 S.Ct. at 2552-53, 91 L.Ed.2d 265. In considering a motion for summary judgment, a court must draw all reasonable inferences in the light most favorable to the non-movants. Spraying Sys. Co. v. Delavan, Inc., 975 F.2d 387, 392 (7th Cir.1992). Thus, if doubts remain, and a reasonable fact-finder could find for the party opposing the motion, summary judgment is inappropriate. Shields Enters., Inc. v. First Chicago Corp., 975 F.2d 1290, 1294 (7th Cir.1992); Wolf v. City of Fitchburg, 870 F.2d 1327, 1330 (7th Cir.1989). B. Plaintiffs’ EEOC Charges 1. Scope of Charge Title VII of the Civil Rights Act of 1964 makes it “an unlawful employment practice for an employer ... to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a)(l). “As a general rule, a Title VII plaintiff cannot bring claims in a lawsuit that were not included in her EEOC charge.” Cheek v. Western and South. Life Ins. Co., 31 F.3d 497, 500 (7th Cir.1994) (citing Alexander v. Gardner-Denver Co., 415 U.S. 36, 47, 94 S.Ct. 1011, 1019, 39 L.Ed.2d 147 (1974)); Prizevoits v. Indiana Bell Tel. Co., Inc., 882 F.Supp. 787, 791 (S.D.Ind.1995), appeal dismissed, 76 F.3d 132 (7th Cir.1996). Defendants maintain that plaintiffs’ disparate impact and treatment claims were not raised in their EEOC charges, and therefore should be dismissed. Defendants’ Br. at 2 n. 2. Plaintiffs disagree, and maintain that their charges adequately implicated these claims, notwithstanding that their present legal theories were not mentioned by name. Plaintiffs’ Br. at 22-24. EEOC charges are rarely written by lawyers. Therefore, where an alleged victim of sexual harassment has “made sufficiently like or reasonably related allegations in her charges to the Equal Employment Opportunity Commission to support, and out of which could grow or reasonably be expected to grow, the ... allegations in her judicial complaint,” Jenkins v. Blue Cross Mut. Hosp. Ins., Inc., 538 F.2d 164, 165 (7th Cir.) (en banc), cert. denied, 429 U.S. 986, 97 S.Ct. 506, 50 L.Ed.2d 598 (1976) a plaintiff will not be denied her day in court on the basis of an allegedly faulty EEOC charge. Babrocky v. Jewel Food Co., 773 F.2d 857, 864 (7th Cir.1985) (“The standard is a liberal one in order to effectuate the remedial purposes of Title VII, which itself depends on lay persons, often unschooled, to enforce its provisions.”). Nonetheless, a plaintiff may not contend that a reasonable relationship exists between an EEOC charge and a complaint merely because the claims contained in each share the general designation of sex discrimination. Cheek, 31 F.3d at 500 (stating that “[b]eeause an employer may discriminate on the basis of sex in numerous ways, a claim of sex discrimination in an EEOC charge and a claim of sex discrimination in a complaint are not alike or reasonably related just because they both assert forms of sex discrimination.”); Weiss v. Coca-Cola Bottling Co., 990 F.2d 333, 337 (7th Cir.1993) (finding that plaintiffs “job transfer” sexual harassment claim exceeded scope of EEOC charge regarding training, discharge and hostile environment sexual discrimination claims); Prizevoits, 882 F.Supp. at 791 (noting that “[d]ifferent claims of sex discrimination are not necessarily reasonably related to each other”). Thus, while there is no expectation that a layperson filing a charge of discrimination with the EEOC “artfully draft” that charge, a potential plaintiff “must at least have described, with some degree of specificity, the conduct she considered discriminatory.” Cheek, 31 F.3d at 502. The afore-referenced principles make it clear that Plaintiffs’ EEOC charges do not reasonably relate to the disparate impact and treatment claims they now seek to pursue in this litigation. a. Plaintiffs’ Disparate Impact Claim “A disparate impact exists where a specified employment practice, although neutral on its face, has a disproportionally negative effect on members of a legally protected class.” Vitug v. Multistate Tax Comm'n, 88 F.3d 506, 513 (7th Cir.1996) (citing Watson v. Fort Worth Bank & Trust, 487 U.S. 977, 986-87, 108 S.Ct. 2777, 2784-85, 101 L.Ed.2d 827 (1988)). In order to state a prima facie case of disparate impact, a plaintiff must first identify the specific employment practices allegedly responsible for the disproportionate impact, and secondly indicate the cause of that impact using statistical evidence. Vitug, 88 F.3d at 513; Daniels v. Pipefitters' Assoc. Local Union No. 597, 945 F.2d 906 (7th Cir.1991) (race discrimination), cert. denied, 503 U.S. 951, 112 S.Ct. 1514, 117 L.Ed.2d 651 (1992). Plaintiffs’ charges make no mention of employment practices with an allegedly skewed negative effect on women at Mercury. All three charges contain general language indicating that each plaintiff believed she was discriminated against in violation of Title VII on the basis of her sex. Defendants’ Ex. A. More specifically, Brooks’ charge states that she was “subjected to verbal abuse” and that she was “offended” by comments that “referenced [her] sex and weight.” Defendants’ Ex. A (Brooks’ EEOC charge). Nowlin’s charge states that she was “sexually harassed by Jim Johnson, Branch Manager” even after he was “made aware that his advances were unwelcome.” Defendants’ Ex. A (Nowlin EEOC Charge). Van Jelgerhuis’ charge states that she and others were “subjected to sexual harassment and a hostile work environment” at the hands of Johnson. Her amended charge asserts that Mercury and Johnson were providing her prospective employers with a “negative impression” of her “in retaliation for filing the initial [EEOC] charge.” Defendants’ Ex. A (Van Jelgerhuis EEOC charges). None of plaintiffs’ charges reasonably implicates Mercury’s employment practices. Accordingly, summary judgment is granted on the disparate impact claim of Plaintiffs’ Complaint. b. Plaintiffs’ Disparate Treatment Claim Summary judgment is likewise appropriate on plaintiffs’ claim that they endured disparate treatment “with respect to conditions and hours of employment.” Plaintiffs’ Complaint (Count IV). The Seventh Circuit has made clear that a general charge to the EEOC will not suffice to allow a plaintiff to proceed into court on legal theories and facts not at least alluded to previously in an EEOC charge. Rush v. McDonald's Corp., 966 F.2d 1104, 1112 (7th Cir.1992). The EEOC charges filed by plaintiffs all point to a claim of hostile work environment. Although, at first blush, an EEOC charge with information sufficient to assert a hostile work environment claim might arguably extend to a claim of disparate treatment, cf. Vitug, 88 F.3d at 513 (“Disparate treatment, ‘the most easily understood type of discrimination,’ occurs when a plaintiff is intentionally treated less favorably than others simply because of his race, color, religion, sex or national origin.” (quoting Watson, 487 U.S. at 985-86, 108 S.Ct. at 2784), plaintiffs failed to include in their charges any specific or even general references to the alleged disparate treatment practices they now seek to redress in this court. See Plaintiffs’ Br. at 24 n. 14 (describing different work expectations as well as different schedule requirements for men and women in the Mercury’s Southside office); cf. Chambers v. American Trans Air, Inc., 17 F.3d 998, 1003 (7th Cir.) (plaintiffs EEOC charge fairly contained disparate treatment claim where she described that male employees received greater compensation than females), cert. denied, — U.S.-, 115 S.Ct. 512, 130 L.Ed.2d 419 (1994). Because their EEOC charges made no mention of different work schedules or compensation for the male and female employees at Mercury, plaintiffs’ allegations of disparate treatment must be dismissed. Summary Judgment accordingly is granted on Plaintiffs’ disparate treatment claims. 2. 300-Day Window As a general rule, in a “deferral state,” such as is Indiana, a plaintiff must file an EEOC charge within 300 days of the occurrence of the event that forms the basis of the complaint. Doe v. R.R. Donnelley & Sons Co., 42 F.3d 439, 445 (7th Cir.1994) (Indiana); Koelsch v. Beltone Elecs. Corp., 46 F.3d 705, 707 (7th Cir.1995) (Illinois). Ap plying this rule, Van Jelgerhuis may not seek relief for allegedly discriminatory events occurring before October 16,1993; Brooks may not seek relief for events prior to December 9, 1993; and Nowlin, not prior to December 17, 1993. This does not present a bar to relief for any events alleged by Nowlin; on the other hand, Van Jelgerhuis clearly, and Brooks somewhat vaguely, both seek to include events that occurred more than 300 days prior to the filing of their charges. Defendants devoted a single, footnote paragraph to this issue and misidentified the dates prior to which relief would generally be barred under the 300-day rule. See Defendants’ Br. at 28 n. 13. The “continuing violation” theory allows a plaintiff to be eligible for relief on an otherwise time-barred act if the plaintiff can successfully link it with an act occurring within the limitations period. Selan v. Kiley, 969 F.2d 560, 564 (7th Cir.1992); Malhotra v. Cotter & Co., 885 F.2d 1305, 1310 (7th Cir.1989) (stating “[t]here must be a violation within the period of the statute of limitations. If having proved such a violation, the plaintiff goes on to prove that it began earlier and that its earlier manifestation caused him additional injury, he can obtain a remedy for the increment as well as for the injury inflicted by the recent violation.”). A claim of hostile-work environment frequently involves a continuing violation. See, e.g., Saxton v. American Tele. & Tele. Co., 10 F.3d 526, 532 n. 1 (7th Cir.1993); Purrington v. University of Utah, 996 F.2d 1025, 1028 (10th Cir.1993) (quoting Waltman v. Int'l Paper Co., 875 F.2d 468, 476 (5th Cir.1989); Stephenson v. Aluminum Co. of America, 915 F.Supp. 39, 49 (S.D.Ind.1995). There must be a “sufficiently close nexus” between and among the allegedly discriminatory acts in order for there to be a continuing violation, rather than “ ‘merely discrete, isolated, and completed ... individual violations.’ ” Doe, 42 F.3d at 446 (citation omitted). In Selan, the Court of Appeals listed three factors properly considered in determining whether a nexus is sufficiently close to justify extending the limitations period. Id. at 565. The first factor relates to subject matter: “Do the alleged acts involve the same type of discrimination, tending to connect them in a continuing violation?”; the second, to frequency: “Are the alleged acts recurring ... or more in the nature of an isolated work assignment or employment decision?”; the third, to permanence: “Does the act have the degree of permanence which should trigger an employee’s awareness of and duty to assert his or her rights ... ?”. Selan, 969 F.2d at 565. It is the third factor that has prompted courts to characterize the continuing violations doctrine as a variation on the theme of equitable tolling. See, e.g., Galloway v. General Motors Serv. Parts Operations, 78 F.3d 1164, 1166 (7th Cir.1996) (“What is true is that standard principles of limitations law, notably the discovery doctrine and the doctrines of equitable estoppel and equitable tolling, excuse the claimant from having to file before it is feasible for him to do so, and these principles apply to cases brought under Title VIL”); Moskowitz v. Trustees of Purdue Univ., 5 F.3d 279, 282 (7th Cir.1993) (noting that the result of applying the continuing violations doctrine “follows directly from the doctrine of equitable tolling.”). The Seventh Circuit recently articulated the “principle ... that ... organizes the complex and diffuse case law on continuing violations under Title VII [as: a] plaintiff may not base her ... suit on conduct that occurred outside the statute of limitations unless it would have been unreasonable to expect the plaintiff to sue before the statute ran on that conduct, as in a ease in which the conduct could constitute, or be recognized, as actionable harassment only in the light of events that occurred later, within the period of the statute of limitations.” Galloway, 78 F.3d at 1167. In this ease, Johnson’s alleged actions towards plaintiffs were basically of the same ilk and, if true, occurred with unfortunate regularity. Cf. Ficek v. Griffith Lab., Inc., No. 93-C-6178, 1995 WL 42081, at *5 (N.D.Ill. Feb. 1, 1995) (stating that ongoing harassment sustained continuing violation doctrine where “the acts [were] all similar in that they had only one objective ... — to belittle [plaintiff].”). More significantly, none of the harassing acts described by either Van Jelgerhuis or Brooks, was of such a permanent nature that their hostile work claims ought to have been triggered at a particular point significantly earlier than the 300-day period prior to their EEOC-filing dates. In Galloway, the Seventh Circuit applied the continuing violations doctrine, stating that defendant’s “repeated ‘sick bitch’ comments ... [were] just the kind of verbal conduct that it would not be reasonable to expect an employee to base suit on the first time it occurred____ But if the comment were repeated daily over a period of years its cumulative effect would be much greater.....”. 78 F.3d at 1167. The Galloway holding applies perforce where a supervisor’s comments were repeated with the frequency described by plaintiffs for a period of over a year and a half. This is especially true where as part of the alleged pattern of harassment described, the defendant behaved strategically to manipulate not only his victims’ environment, but also their reactions to his abuse. According to Van Jelgerhuis: Mr. Johnson knew how far he could push you and how much you could take and he would push you as far as you could go and push you almost to that line and then when you got to that point, he would back off, when you were ready to go to Dan Smith or you were ready to go to whoever, and then he’d ease up a little bit and come back in and start it all over again. Van Jelgerhuis Dep. at 299-300; see also id. at 153. Both Van Jelgerhuis and Brooks contend that Johnson harassed them throughout the 300-day period prior to their EEOC filings. Van Jelgerhuis maintains that she sent a letter to Mercury’s human resources office during the 300-day period prior to her EEOC filing, and she maintains she spoke with her operations manager on two occasions (one at an unspecified time). Doe, 42 F.3d at 446 (declining to apply continuing violations doctrine “because no harassment event occurring during the violation period was ever brought to the attention of [defendant] ... there is no violation during the limitation period that can serve as the anchor for the earlier conduct.”). Both plaintiffs describe Johnson’s behavior as part of an ongoing course of similar and frequent harassment. It is difficult, to say the least, to pinpoint precisely when a plaintiff ought to know that the harassment she is enduring rises to the level of a hostile environment claim. Cf. Galloway, 78 F.3d at 1166 (“Sexual harassment serious enough to constitute unlawful discrimination on grounds of sex is often a cumulative process rather than a onetime event. In its early stages it may not be diagnosable as sex discrimination, or may not cross the threshold that separates the nonactionable from the actionable____”). Defendants have not moved specifically to exclude any alleged event from consideration of plaintiffs’ hostile work environment claims. Cf. Saxton, 10 F.3d at 532 n. 11 (“because [defendant] has devoted no more than a skeletal paragraph to this issue, and because the record does not clarify the timing of the last acts of harassment, we will not undertake to parse [plaintiffs] claims in an effort to weed out time-barred incidents.’ ”); Young v. Will County Dep't of Public Aid, 882 F.2d 290, 292 (7th Cir.1989) (stating, on motion for summary judgment, that “[a]ll doubts on jurisdictional timeliness are to be resolved in favor of trial.”). Thus, applying the continuing violations theory, plaintiffs Van Jelgerhuis and Brooks will not be barred from including allegedly discriminatory events occurring more than 300 days prior to their EEOC filings in establishing their entitlement to relief. C. Title VII: Hostile Work Environment It is well established that Title VII embraces sex discrimination claims based on the theory of a hostile work environment. See, e.g., Harris v. Forklift Sys., Inc., 510 U.S. 17, 21, 114 S.Ct. 367, 370, 126 L.Ed.2d 295 (1993); Meritor Sav. Bank, FSB v. Vinson, 477 U.S. 57, 64, 106 S.Ct. 2399, 2404, 91 L.Ed.2d 49 (1986); Dey v. Colt Constr. & Dev. Co., 28 F.3d 1446, 1453 (7th Cir.1994). The test for an actionable hostile work environment under Title VII includes both an objective and subjective inquiry. Dey, 28 F.3d at 1454; Ripberger v. Western Ohio Pizza, Inc., 908 F.Supp. 614, 618-19 (S.D.Ind.1995). If a work environment “would reasonably be perceived, and is perceived, as hostile or abusive, there is no need for it also to be psychologically injurious.” Harris, 510 U.S. at 22, 114 S.Ct. at 371; Dey, 28 F.3d at 1453 & n. 7. The allegedly discriminatory conduct must have the “purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.” Meritor, 477 U.S. at 65, 106 S.Ct. at 2405; Ripberger, 908 F.Supp. at 618. In addition, in order for harassment to be actionable under Title VII, it must have occurred because of a plaintiffs sex, although “[s]ex discrimination, including harassment, can take many forms and is not limited to sexual behavior that is harassing.” Bilbrey v. Werts Novelty Co., 881 F.Supp. 370, 375 (S.D.Ind.1994); see also Ripberger, 908 F.Supp. at 619. 1. Objective Harassment The bounds of what, objectively, constitutes a hostile work environment elude precise demarcation. See, e.g., Harris, 510 U.S. at 22, 114 S.Ct. at 371 (“[t]his is not, and by its nature cannot be, a mathematically precise test.”); Baskerville v. Culligan Int'l Co., 50 F.3d 428, 430 (7th Cir.1995). Certainly, harassment “must be sufficiently severe or pervasive ‘to alter the conditions of the victim’s employment and create an abusive working environment.’” Meritor, 477 U.S. at 67, 106 S.Ct. at 2405 (quoting Henson v. City of Dundee, 682 F.2d 897, 902 (11th Cir.1982)). Factors informing whether a hostile work environment exists include “the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.” Harris, 510 U.S. at 23, 114 S.Ct. at 371. Yet “no single factor is required,” and whether a work environment is objectively hostile “can be determined only by looking at all the circumstances.” Id. Isolated incidents will not by themselves create an actionable hostile work environment, Chalmers v. Quaker Oats Co., 61 F.3d 1340, 1345-46 (7th Cir.1995) (“[t]hough sporadic behavior, if sufficiently abusive, may support a Title VII claim, success often requires repetitive misconduct.”); Koelsch, 46 F.3d at 708 (“Isolated and innocuous incidents do not support a finding of sexual harassment”), however it is clear that there is no “magic number” of discriminatory events required to trigger Title VII. Doe, 42 F.3d at 445; Rodgers v. Western-Southern Life Insurance Co., 12 F.3d 668, 674 (7th Cir.1993). In Baskerville, the Seventh Circuit stated that “[d]rawing the line is not always easy.” 50 F.3d at 430. The court has provided guidance, explaining that “[o]n one side [of the line] lie sexual assaults; other physical contact, whether amorous or hostile, for which there is no consent express or implied; uninvited sexual solicitations; intimidating words or acts; obscene language or gestures; pornographic pictures.” Id. On the other side, “the occasional vulgar banter, tinged with sexual innuendo, of coarse or boorish workers.” Id.; see also Carr v. Allison Gas Turbine Div., Gen. Motors Corp., 32 F.3d 1007, 1010 (7th Cir.1994). Thus, in Baskerville, where the defendant did not threaten plaintiff, expose himself to her, or say “anything to her that could not be repeated on primetime television,” let alone invite her “explicitly or by implication to have sex with him,” the court held that, objectively, plaintiff could not state a claim for hostile work environment. Baskerville, 50 F.3d at 431. Both Van Jelgerhuis and Brooks describe Johnson as directing extremely offensive, sexual comments at them in language not appropriate for late-night cable, let alone primetime television. All three plaintiffs complain about Johnson’s persistent comments regarding their appearances. Johnson allegedly routinely called the plaintiffs “fat” and “ugly”, and he placed particular emphasis on how their looks related to their sex lives. Johnson also reportedly commented to more than one plaintiff on the size of her breasts, and he allegedly asked plaintiffs inappropriate questions about their sexual relationships. Cf. McCleland v. Montgomery Ward & Co., Inc., No. 95-C-237, 1995 WL 476607 (N.D.Ill. Aug. 10, 1995) (denying summary judgment where plaintiff alleged hostile work environment based on events occurring over five-month period, including that defendant asked “unsolicited questions about her boyfriend and told her he could satisfy her better than her boyfriend.”). Nowlin maintains that Johnson often “rubbed up” against her. All three plaintiffs contend that there were additional incidents of harassment by Johnson not referenced specifically in their depositions. Van Jelgerhuis Dep. at 277; Brooks Dep. at 107; Nowlin Dep. at 72-73; cf Dey, 28 F.3d at 1456-57 (denying summary judgment where plaintiff could recall only the “most blatant” five incidents of harassment over a two-and-a-half- year period, yet maintained “she was subjected to almost daily comments, gestures and innuendo of a sexual nature____”). Drawing all reasonable inferences in favor of plaintiffs, they were subjected to an objectively hostile work environment at Mercury’s Southside Branch. Plaintiffs describe an ongoing campaign of sexual harassment waged by Johnson — not merely discrete, isolated incidents of inappropriate behavior. Cf. Koelsch, 46 F.3d at 708 (holding that no hostile work environment objectively existed where plaintiff alleged “two seemingly isolated incidents”); Saxton, 10 F.3d at 534, 535 (finding that plaintiff failed to demonstrate objective hostile work environment where she alleged “relatively limited” harassment after which defendant had “long since stopped pursuing [plaintiff]”); Weiss, 990 F.2d at 337 (affirming summary judgment where plaintiff alleged “relatively isolated” incidents of relatively innocuous acts by defendant). This inference is strengthened when the environment, as described by plaintiffs, is considered as the sum of their collective experiences. Courts may consider third parties’, or co-plaintiffs’, impressions of and experiences in a work environment when a plaintiff maintains she was aware of defendant’s sexual harassment of other employees in a workplace. The question of whether third parties’ experiences may be marshalled by a Title VII plaintiff to sustain a claim that the environment was hostile to women has never been directly addressed by the Seventh Circuit; however, it has been implicitly answered. See, e.g., Brooms v. Regal Tube Co., 881 F.2d 412, 419 (7th Cir.1989) (endorsing objective and subjective analysis for hostile environment claim and listing factors for consideration endorsed by Sixth Circuit as including “the background and experience of the plaintiff [and] her coworkers”) (citing Rabidue v. Osceola Refining Co., 805 F.2d 611 (6th Cir.1986), cert. denied, 481 U.S. 1041, 107 S.Ct. 1983, 95 L.Ed.2d 823 (1987); Dey, 28 F.3d 1446, 1456 (noting that general, gender-related comments not directed specifically at plaintiff would be actionable under Title VII) (citing 58 Fed.Reg. 51266, 51269 (proposed 29 CFR § 1609.1(d)) (“Harassing conduct may be challenged even if the complaining employee(s) are not specifically intended targets of the conduct.”); Dockter v. Rudolf Wolff Futures, Inc., 913 F.2d 456, 460 n. 4 (7th Cir.1990) (referencing corroborating testimony of two non-party female employees’ for objective hostile environment analysis). The Seventh Circuit routinely includes among the factors to consider in assessing the objective hostility of a work environment in claims involving race discrimination, “the nature of the alleged harassment, the background and experience of the plaintiff [and] her coworkers....” See, e.g., Rodgers v. Western-Southern Life Ins. Co., 12 F.3d 668, 674 (7th Cir.1993); Daniels v. Essex Group, Inc., 937 F.2d 1264, 1274 (7th Cir.1991). However, this language has not been generally adopted in the context of environment claims based on sex. But see Brooms, 881 F.2d at 419 (early hostile environment claim referencing factors typically listed as appropriate for consideration in context of claim on basis of race). Other circuits that have directly tackled this issue consistently have held in favor of referencing third-party evidence to determine whether a work environment was hostile to women on the basis of their sex. Hicks v. Gates Rubber Co., 833 F.2d 1406, 1415-16 (10th Cir.1987); Hall v. Gus Constr. Co., Inc., 842 F.2d 1010, 1014-15 (8th Cir.1988) (holding appropriate the “consider[ation of] all of the women’s claims together in determining that the harassment was sufficiently pervasive and severe to constitute a violation of Title VII” and that “evidence of sexual harassment directed at employees other than the plaintiff is relevant to show a hostile work environment.”); Jones v. Flagship Int'l, 793 F.2d 714, 721 n. 7 (5th Cir.1986) (pre-Harris case stating that incidents of sex harassment reported by female employees would be considered in hostile environment claim only with evidence that those incidents “affected [plaintiffs] psychological well-being.”), cert. denied, 479 U.S. 1065, 107 S.Ct. 952, 93 L.Ed.2d 1001 (1987); Vinson v. Taylor, 753 F.2d 141, 146 (D.C.Cir.1985) (stating that “evidence tending to show [defendant’s] harassment of other women working alongside [plaintiff] is directly relevant to the question whether he created an environment violative of Title VII. Even a woman who was never herself the object of harassment might have a Title VII claim if she were forced to work in an atmosphere in which such harassment was pervasive”), aff'd on other grounds, Meritor, 477 U.S. at 57, 106 S.Ct. at 2399. District courts in this circuit who have struggled with the question have almost invariably considered the complaints of non-plaintiffs in determining whether an environment was hostile to women on the basis of their sex existed in a workplace. See, e.g., Valadez v. Uncle Julio's of Illinois, Inc., 895 F.Supp. 1008, 1013 (N.D.Ill.1995) (stating that “the court can consider evidence of sexual harassment directed at other employees of the same sex as plaintiff” when determining existence of hostile work environment); Jansen v. Packaging Corp. of America, 895 F.Supp. 1053, 1062 n. 11 (N.D.Ill.1995) (noting that “[c]ourts have cited the earlier or concurrent harassment of third parties as evidence that the currently-charged harassment was sufficiently pervasive or severe to constitute a violation of Title VII____ Less frequently such third parties’ testimony is offered to establish an employer’s awareness of a hostile work environment.”); but see Janopoulos v. Harvey L. Walner and Associates, 866 F.Supp. 1086, 1092 (N.D.Ill.1994) (declining to permit testimony of other employees to establish existence of hostile environment, limiting it to the question of employer notice). It is difficult to imagine a convincing rationale for a contrary rule in hostile environment claims. As the Tenth Circuit stated in Hicks: Hicks, 833 F.2d at 1415-16; see also Creamer v. Laidlaw Transit, Inc., 86 F.3d 167, 171 (10th Cir.1996) (“Although ‘evidence of a general work atmosphere, including evidence of harassment of other women, may be considered in evaluating a claim’ of sexual harassment, the plaintiff ‘may only rely on evidence relating to harassment of which she was aware during the time she was allegedly subject to a hostile work environment’”) (quoting Hirase-Doi v. U.S. West Communications, Inc., 61 F.3d 777, 782 (10th Cir.1995)). Thus, where a plaintiff maintains she was aware of a defendant’s hostile treatment of other women in a work environment she will not be precluded from having those other allegedly discriminatory incidents be considered in the determination of whether a work environment was objectively hostile. A reasonable trier of fact could determine that, in addition to their own first-hand experiences with Johnson, plaintiffs were also aware of the more widespread hostile environment Johnson created by his actions towards other women in the Southside Branch. There exist genuine issues of material fact regarding whether plaintiffs were aware of Johnson’s harassment of each other, as well as of other women in the office. See, e.g., Van Jelgerhuis Dep. at 216 (“I’ve seen Jim Johnson stand in his office and holler about the girl’s chest in the front of the office.”); Plaintiffs’ Ex. B at 3(a) (Brooks describing comments she heard Johnson make regarding Van Jelgerhuis); Nowlin Dep. at 21 (stating that she and Brooks spoke frequently during their employment at Mercury); Nowlin Dep. at 68 (stating that Johnson was “always” making comments about Brooks’ appearance). Whether incidents of sexual harassment directed at employees other than the plaintiff can be used as proof of the plaintiff’s claim of a hostile work environment, the answer seems clear: one of the critical inquiries in a hostile environment claim must be the environment. Evidence of a general work atmosphere therefore — as well as evidence of specific hostility directed toward the plaintiff — is an important factor in evaluating the claim. Plaintiffs individually, as well as collectively, describe an ongoing course of sexual harassment waged against them by Johnson that objectively rises to a level of hostile work environment. Accordingly, defendants are not entitled to summary judgment on this basis. 2. Subjective Harassment There also remain genuine issues of material fact that preclude summary judgment on the question of whether plaintiffs subjectively experienced a hostile work environment at Mercury’s Southside Branch. Plaintiffs describe feeling “humiliated,” “embarrassed” and demeaned by Johnson’s behavior. See, e.g., Van Jelgerhuis Dep. at 267; Brooks Dep. at 102; Nowlin Dep. at 59. Van Jelgerhuis states that after the February 1993 incident she left work; Brooks stated that after Johnson made comments to her, she would just turn around and walk out of his office. Brooks Dep. at 104, 117-118; Cf. Dey, 28 F.3d at 1454 (denying summary judgment where plaintiff “maintained that on more than one occasion, [defendant’s] comments caused her to walk out of his office.”). Nowlin’s letter of resignation stated she was leaving because of a hostile work environment. Plaintiffs’ Ex.C. And Van Jelgerhuis complained that no one should have to work under the conditions as they were at Mercury. Van Jelgerhuis Dep. at 152, 269. Defendants maintain, however, that plaintiffs participation in bawdy office talk evidences that they were not as subjectively offended by their environment as they now claim. Defendants’ Br. at 15. However, a woman does not forfeit her right to be free from sexual harassment by virtue of her participation in sexual banter. See, e.g., Carr, 32 F.3d at 1011 (rejecting idea of “welcome sexual harassment,” while acknowledging that “[a] plaintiff’s words, deeds and deportment can east light on whether her eoworkers’ treatment of her was unwelcome and should have been perceived as such by them and their supervisors”). While plaintiffs’ comportment and behavior in the Mercury office are certainly relevant to evaluating their subjective perception of the environment there, a reasonable trier of fact could determine that plaintiffs’ interactions with their coworkers were voluntary and non-threatening, while the dynamic created by Johnson was hostile and intimidating. See Van Jelgerhuis Dep. at 102 (distinguishing coworkers’ conversations from the interaction with Johnson, stating “I could say to her ... I don’t think that’s appropriate and not fear for being fired or discharged from my job.”). Comments and behavior that may be perceived as innocuous, albeit lewd, banter between coworkers may justifiably be perceived as hostile and abusive if directed by a male supervisor to a female subordinate. Rodgers, 12 F.3d at 675 (“a supervisor’s use of the term impacts the work environment far more severely than use by co-equals.”); see also Carr, 32 F.3d at 1011 (“The asymmetry of positions must be considered.”). Finally, defendants maintain that plaintiffs’ actions towards Johnson fatally undermine their claim that they perceived him to have created a hostile work environment at Mercury. Defendants point to a number of occasions when plaintiffs sought advice from him, in one ease borrowed money from him for a sister’s abortion, and, in another instance, actually enlisted his help to stop a former lover who was attempting to blackmail Van Jelgerhuis. See, e.g., Brooks Dep. at 41, 44; Van Jelgerhuis Dep. at 207-08, 213-14. However, again, plaintiffs’ behavior does not necessarily refute their claim that they felt Johnson harassed and humiliated them. Cf. Dey, 28 F.3d at 1455 (stating that plaintiffs seeking legal and financial advice from defendant did “not necessarily contradict her assertions that [defendant’s] conduct consistently upset and embarrassed her”). A reasonable trier of fact could determine that plaintiffs felt intimidated and mistreated by Johnson, yet still found themselves compelled to appeal to him when their other options were few. 3. “On The Basis of Sex” Whether Johnson harassed the plaintiffs on the basis of their sex again creates a genuine issue of material fact. All of the plaintiffs concede that Johnson was preoccupied generally with obesity. Van Jelgerhuis Dep. at 234; Brooks Dep. at 39, 95; Nowlin Dep. at 56. They also acknowledge that Johnson belittled men and women employees in the southside branch. See, e.g., Van Jelgerhuis Dep. at 237; Brooks Dep. at 95. However, drawing all reasonable inferences in favor of plaintiffs, it is clear that each had demeaning encounters with Johnson that were clearly sex based. Cf. Hutchison v. Amateur Elec. Supply, Inc., 42 F.3d 1037, 1043 (7th Cir.1994) (“It blinks reality to claim that sexual conduct which demeans women by a man in a position of power, even if not directed at a specific woman victim, equally impacts male and female subordinates.”). A reasonable trier of fact could determine that Johnson harassed both his women and men employees and that he discriminated against plaintiffs on the basis of their sex. These would not necessarily be inconsistent determinations, and on this motion for summary judgment, give rise to an inference supportive of plaintiffs’ accounts of events at the Mercury Southside Branch. 4. Defendant’s Liability Under Title VII a. Claims against Johnson In Equal Employment Opportunity Commission v. AIC Security Investigations, Ltd., the Seventh Circuit held that individuals cannot be liable under Title VII because the statute’s use of the term “employer” does not embrace individual liability. 55 F.3d 1276, 1281 (7th Cir.1995). Plaintiffs do not disagree. Accordingly, Johnson personally is entitled to summary judgment on the Title VII claims against him. b. Claims against Mercury An employer is not strictly liable for a hostile work environment created by its employees. Meritor, 477 U.S. at 72, 106 5. Ct. at 2408 (holding that agency principles “place some limits on the acts of employees for which employers under Title VII are to be held responsible.”); Doe, 42 F.3d at 446 (“employers are not absolutely liable for workplace harassment”). It is clear that if a hostile work environment is created by coworkers of a victim, the standard for an employer’s liability is negligence. Carr, 32 F.3d at 1009; Guess v. Bethlehem Steel Corp., 913 F.2d 463, 465 (7th Cir.1990). In the case of a hostile work environment created by a supervisor, however, there is some uncertainty regarding the appropriate standard of employer liability. In Meritor, the Supreme Court specifically ruled that the lower court erred in “concluding that employers are always automatically liable for sexual harassment by their supervisors,” invoking traditional agency principles to determine employer liability. Id. at 58, 106 S.Ct. at 2401 (emphasis added). While there is little question regarding what constitutes actual authority for an agent, see, e.g., Ripberger, 908 F.Supp. at 622 (stating that sexual harassment “cannot be considered to be authorized, appropriate, foreseeable, or ‘actuated by an intent to serve’ the employer”) (quoting Restatement § 235 cmt. a), the question of what constitutes apparent authority has left the door open for courts to impose strict liability on employers in some, though not clearly defined instances. For example, in Baskerville the Seventh Circuit stated that: [a]n employer is not strictly hable for sexual harassment of one worker by another unless, perhaps, the harassment takes the form, not here alleged, of an abuse of authority, as where a supervisor threatens to fire a subordinate if she refuses to have sex with him. In such cases, a number of courts treat the supervisor as the employer, whether correctly or not we need not decide. (Neither the Supreme Court nor our court has had occasion to decide the question.) 50 F.3d at 431-32. And, in Saxton, it stated: [o]f course, if someone in the employer’s decision-making hierarchy engages in harassment, the employer may be held liable regardless of whether it could reasonably have foreseen or prevented the misconduct, for in that instance, the acts of the managerial employee constitute the acts of the employer. 10 F.3d 526, 536 n. 19. Some courts, in an effort to clarify the concept of apparent authority, have used an employee’s ability to “hire and fire” as a means to determine whether the employer should be strictly liable for the supervisor-created hostile environment. Shaper v. Upjohn Co., 913 F.2d 398, 405 (7th Cir.1990); Volk v. Coler, 845 F.2d 1422, 1436 (7th Cir.1988); North v. Madison Area Ass'n for Retarded Citizens-Dev. Ctrs. Corp., 844 F.2d 401, 407 (7th Cir.1988); Ibrahim v. Holidays Inn, Inc., No. 95-C-4316, 1996 WL 199743 (N.D.Ill. Apr. 23, 1996); see also Hunter v. Allis-Chalmers Corp., 797 F.2d 1417, 1422 (7th Cir.1986), but see Brooms, 881 F.2d at 421 (labelling Hunter language “dicta”). It is undisputed that Johnson was the supervisor of the Mercury Southside Branch with power to hire and fire employees. However, whether a standard other than negligence governs Mercury’s liability for the allegedly hostile work environment at the Southside Braneh need not be resolved at this time, because Mercury may be liable for Johnson’s actions applying a negligence standard. Mercury maintains that because an employer may not be held strictly liable for the acts of an employee, it is entitled to summary judgment on Plaintiffs’ Title VII claim. However, an employer, “provided it has used due care in hiring the offending employee in the first place, is liable for that employee’s torts against a coworker only if, knowing or having reason to know of the misconduct, the employer unreasonably fails to take appropriate corrective action.” Carr, 32 F.3d at 1009; Guess, 913 F.2d at 465. Defendant also contends that summary judgment is warranted because Plaintiffs failed to access the Company’s designated channels to report their alleged harassment. Mercury insists that, notwithstanding that Van Jelgerhuis made a number of attempts to report Johnson, none of the people with whom she spoke had a duty to relay that information to the Company. In order for liability to attach, an “agent must have a duty to speak with respect to the specific item of knowledge.” Doe, 42 F.3d at 446-47; Juarez v. Ameritech Mobile Communications, Inc., 957 F.2d 317, 321 (7th Cir.1992) (citations omitted) (“ ‘the agent must have not just a duty in relation to the subject matter, but a duty to speak to his principal about the specific item of knowledge.’ ”). 1. Van Jelgerhuis Van Jelgerhuis concedes that she never contacted Smith, the Mercury employee designated to receive complaints of sexual harassment. Van Jelgerhuis Dep. at 299-301. She admits this is the case, notwithstanding that during the time Johnson was harassing her, she had a conversation with Smith regarding the unrelated harassment of another Mercury employee. Van Jelgerhuis Dep. at 301. However, Van Jelgerhuis maintains that she did notify other appropriate managers at Mercury of Johnson’s harassment. She contends that she informed Johnson’s counterpart at Mercury’s Anderson Branch of the February 1993 Johnson dream incident. Van Jelgerhuis Dep. at 153. Van Jelgerhuis maintains that she also spoke on at least two different occasions with her direct supervisor, Joe Carson, about the problems with Johnson. Van Jelgerhuis Dep. at 151-52, 164. Although a subordinate of Johnson’s, it is undisputed that Carson was the Operations Manager at the Southside Branch. See Defendants’ 56.1 Statement at 2. In addition, Van Jelgerhuis maintains that she attached a three-page letter to a Mercury workplace survey distributed by Mercury’s president, John Brincat. Van Jelgerhuis Dep. at 144, 150. Although she acknowledges that the letter identified neither the writer nor her branch, Van Jelgerhuis maintains that she described in graphic terms the work environment she endured. Van Jelgerhuis Dep. at 148-50 (describing letter’s contents as including accounts of Johnson’s behavior in the office as well as recommendation that “someone investigate the office” because the work environment was insufferable). The only response that Van Jelgerhuis ever received from Mercury regarding her complaints came from Joe Carson, who said: What do you want me to do[?] If I say it to him [Johnson], he’s going to ride you harder____ If I don’t say anything you’re going to be upset____ What do you expect me to do about it? Van Jelgerhuis Dep. at 152. Van Jelgerhuis maintains she replied to Carson: “I don’t know what you’re supposed to do about it, Mr. Carson, but we shouldn’t have to go through this day in and day out.” Id. Mercury’s policy prohibiting sexual harassment requires management employees to respond to complaints of sexual harassment. Defendants’ Ex. F (“Appropriate management and supervisory personnel shall take prompt, corrective action when they become aware of sexual harassment.”). There is at least a genuine issue of fact regarding whether Carson and Markle were “appropriate” supervisors upon whom a duty to report sexual harassment was imposed by Mercury’s own policy. Cf. Juarez, 957 F.2d at 321 (finding no duty to report where company’s policy did not require it of supervisor with knowledge of alleged sexual harassment); McCleland v. Montgomery Ward & Co., Inc., No. 95-C-237, 1995 WL 476607, at *9 (N.D.Ill. Aug. 10, 1995) (stating that company policy required managers to report complaints of harassment, thus raising genuine issue of material fact whether duty appropriately imposed). The record is devoid of any evidence that Mercury responded to Van Jelgerhuis’ complaints. Thus, a trier of fact could reasonably find that Mercury was negligent in its handling of the hostile work environment at the Southside Branch. Summary judgment is accordingly denied on Van Jelgerhuis’ Title VII hostile environment claim. 2. Brooks & Nowlin There is also a genuine issue of material fact precluding summaiy judgment on the question of whether Mercury had constructive knowledge of Johnson’s allegedly harassing behavior such that Brooks and Nowlin did not themselves need to report directly Johnson’s harassment. An employer may have constructive knowledge of an employee’s harassment by virtue of prior complaints lodged by other victims regarding the alleged harasser. Hirase-Doi, 61 F.3d at 784; Dey, 28 F.3d at 1458; Paroline v. Unisys Corp., 879 F.2d 100, 107 (4th Cir.1989); Ripberger, 908 F.Supp. at 624; Doe v. R.R. Donnelley & Sons Co., 843 F.Supp. 1278, 1283 n. 2 (S.D.Ind.1994), aff'd, Doe, 42 F.3d 439. Van Jelgerhuis complained twice to Joe Carson, the Operations Manager at the Southside Branch, about the conditions there; she also maintains she contacted the Anderson Branch Supervisor regarding Johnson’s behavior. Finally, there is the anonymous letter Van Jelgerhuis maintains she attached to the Mercury survey distributed at the behest of the company’s president. Although the letter was admittedly anonymous and failed to specify the South-side Branch, it is difficult to imagine an employer reasonably disregarding a three-page letter describing the events represented by Van Jelgerhuis; particularly in response to a company-president endorsed survey purportedly about workplace conditions and when the company’s own procedures invite anonymity. See Defendants’ Ex. G (policy establishing Hotline). Even assigning the letter the slightest weight, however, a reasonable trier of fact could determine that it sufficed to give constructive notice of Johnson’s harassing behavior and the attendant hostile work environment at the Southside Branch, given in addition Van Jelgerhuis’ complaints to Carson and Markle. Accordingly, Mercury’s summary judgment motion is denied on Brooks’ and Nowlin’s Title VII hostile environment claims. 5. Constructive Discharge The viability of plaintiffs’ hostile environment claims under Title VII does not, as defendants maintain, turn on the issue of whether plaintiffs were discharged — constructively or otherwise. Prior to the enactment of the 1991 amendments, under the provisions of Title VII, a victim of Title VII was eligible only for equitable relief. See, e.g., Swanson v. Elmhurst Chrysler Plymouth, Inc., 882 F.2d 1235, 1239-40 (7th Cir.1989) (citing Bohen v. City of East Chicago, 622 F.Supp. 1234, 1244-45 (N.D.Ind.1985), aff'd, 799 F.2d 1180 (7th Cir.1986) (discussing 42 U.S.C. § 2000e-5(g)). However, because equitable relief, such as reinstatement or i