Defining “sexual harassment” in the context of a Title VII claim, the Second Circuit has held that it “includes ‘conduct [that] has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.” ’ Petrosino v. Bell Atlantic, 385 F.3d 210, 220-21 (2d Cir.2004) (quoting Fitzgerald v. Henderson, 251 F.3d 345, 356 (2d Cir.2001), and 29 C.F.R. § 1604.11(a)). The Petrosino Court went on to hold that “incessant sexually offensive exchanges ... and omnipresent sexual graffiti,” when viewed as a whole, could constitute severe or pervasive sexual harassment in the Title VII context. Id. at 221, 223-24. See also Galdieri-Ambrosini v. National Realty & Dev. Corp., 136 F.3d 276, 289 (2d Cir.1998) (<HOLDING>). Further, the Supreme Court has explicitly
holding that sexual harassment need not take the form of sexual advances or other explicitly sexual conduct in order to be actionable under title vii holding that samcscx sexual harassment claims are actionable under title vii holding that samesex sexual harassment claims are not actionable under title vii holding that supervisors questions made two and three times a week about plaintiffs sexual activities constituted actionable sexual harassment holding that noneconomic injury resulting from a hostile environment based on discriminatory sexual harassment is actionable under title vii