in employment, or directly by evidence of retaliatory animus. See Sumner v. U.S.P.S., 899 F.2d 203, 209 (2d Cir.1990); see also Post v. Court Officer Shield #207, 180 F.3d 409, 418 (2d Cir.1999) (“[T]he plaintiff ... need not clearly establish that the defendant harbored retaliatory intent. It is sufficient to allege facts which could reasonably support an inference to that effect.”). Summary judgment is precluded where questions regarding an employer’s motive predominate in the inquiry regarding how important a role the protected speech played in the adverse employment decision. See Piesco v. City of New York, 933 F.2d 1149, 1155 (2d Cir.1991). To satisfy the causal connection requirement of his prima facie case, Franzon must show that his public criticism o 3d 545, 555 (2d Cir.2001) (<HOLDING>); Quinn v. Green Tree Credit Corp., 159 F.3d
holding that a mere allegation of fraud is insufficient to survive a motion to dismiss pursuant to the pslra recognizing that a strong causal connection is required quotation omitted holding that a fourmonth interval was sufficient to support an allegation of a causal connection strong enough to survive a summary judgment motion holding that more than a year between the protected activity and the discharge is not close enough to support the causal connection requirement holding that plaintiffs allegation that defendant conditioned its software on purchase of its hardware was sufficient to survive summary judgment