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On August 1, 2009, FIREsent  a memo to the California Advisory Committee to the U.S. Commission on Civil Rights. The memo explains that colleges and universities must meet their Title IX and Title VI obligations to ban student-on-student harassment under the Civil Rights Act of 1964 when they use a definition of harassment no more strict and no less strict than the specific definition provided by the Supreme Court in Davis v. Monroe County Board of Education (1999). The Davis definition states that conduct must be “so severe, pervasive, and objectively offensive that it effectively bars the victim’s access to an educational opportunity or benefit,” in order to be considered discriminatory harassment. On August 29, 2010, FIREPresident Greg Lukianoff testified before the advisory committee about unconstitutional discriminatory harassment policies at colleges and universities across California.