is based on a retaliatory motive and is reasonably likely to deter the charging party or others from engaging in a protected activity.” Ray v. Henderson, 217 F.3d 1234, 1244 (9th Cir.2000) (citing EEOC Compliance Manual Section 8, “Retaliation,” ¶ 8008 (1998)). This definition includes actions “materially affect[ing] compensation, terms, conditions, or privileges” of employment. 42 U.S.C. § 2000e-2(a)(1); Kortan v. Cal. Youth Auth., 217 F.3d 1104, 1109 (9th Cir.2000). A cut in base pay is clearly such an adverse action, despite, as the district court noted, Little’s “hopes and expectations [of her sales and bonuses] for coming months or years.” See Ray, 217 F.3d at 1241 (9th Cir.2000) (noting that “adverse employment action” is defined broadly); see, e.g., Hashimoto, 118 F.3d at 676 (<HOLDING>). And, of course, termination of employment is
holding that a transfer of job duties can constitute an adverse employment action holding that a negative performance evaluation on its own is insufficient to constitute an adverse employment action as a matter of law holding that termination is an adverse employment action holding negative employee review not adverse until it is used to deny a job opportunity holding that the dissemination of a negative job reference constitutes an adverse employment action