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For example, an employer might design policies and action plans to take reasonable steps to prevent harassment by third parties and put together what appears to be a comprehensive package of measures—though I note how much energy even reading that takes, never mind doing it. None the less, if the employee can point to any single additional reasonable means that the employer could have taken but did not, then the claim could be upheld even if the employer had attempted to do all they could to comply—talk about making workplaces jump through hoops.