In Sandra Bogota, et al. v. The University Club, et al. (Sup. Ct. N.Y. County July 3, 2010), the New York State Supreme Court once again emphasized that it is critical for employers to provide sexual harassment and anti-discrimination training that educates their employees about unlawful discriminatory conduct in a meaningful way. The Court’s decision underscores that perfunctory training and policies will not shield an employer from liability for the discriminatory actions of its employees under New York City law.