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Different Titles, Products May Not Justify Higher Pay For Male Sales Reps

Finding triable issues on whether a female employee performed substantially similar work to male marketing managers despite their different job titles and products, a federal district court in Minnesota denied summary judgment on her Equal Pay Act claim. However, her state-law discrimination claim failed because being excluded from work activities and networking opportunities were not adverse employment actions absent some effect on the employee's ability to perform her job or advance. Her retaliatory failure-to-hire claim also failed because she did not identify a position for which she had applied.

(Berghoff v Patterson Dental Holdings, Inc, DMinn, March 21, 2018, Frank, D.)

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