VII cases. Consequently, courts, speaking in the context of Title VII, have used the term "sex” and "gender" interchangeably to refer simply to the fact that an employee is male or female. See, e.g., Price Waterhouse v. Hopkins, 490 U.S. 228, 239-41, 109 S.Ct. 1775, 1784-86, 104 L.Ed.2d 268 (1989) (using "gender” and "sex” interchangeably). Indeed, the use of “sex” and "gender” interchangeably may impose a useful limit on the term “sex,” which otherwise might be interpreted to include sexual behavior. Some academic writers, however, seek to maintain or to heighten a distinction between the terms "sex” and "gender,” assertin p. 1133 (C.D.Ill.1995) (same) and Raney v. District of Columbia, 892 F.Supp. 283 (D.D.C.1995) (same) with Ashworth v. Roundup Co., 897 F.Supp. 489 (W.D.Wash.1995) (<HOLDING>) and Goluszek v. Smith, 697 F.Supp. 1452
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 samesex sexual harassment claims are not actionable under title vii holding that title vii does not address samesex harassment holding that samcscx sexual harassment claims are actionable under title vii holding that noneconomic injury resulting from a hostile environment based on discriminatory sexual harassment is actionable under title vii