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Ms. Egan notes:
"It remains to be seen whether the Third Circuit will directly address whether the continuing violations doctrine applies to Title IX cases. Institutions and entities in the Third Circuit subject to Title IX should monitor developments regarding the continuing violations doctrine. If the doctrine is ever applied by an appellate court, then such institutions and entities should be aware that if one action, which can be viewed as part of the same persistent, ongoing pattern, occurred within the statute of limitations, then the entire claim will be viable."
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