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Schools are increasingly expected to intervene to prevent the sorts of bullying behavior that can interfere with education. If they do so inadequately, as a number of recent cases show, school districts may be held liable under Title IX for their “deliberate indifference” to harassment that effectively prevents the victim from receiving the benefits of public education. In popular imagination, “bullying” usually consists of one aggressor terrorizing one victim, sometimes with the assistance or tacit approval of other students. But least with respect to the many cases of students being targeted because they were, or were perceived to be, gay, this perception is overly narrow. In virtually all of the cases on record over the past dozen or so years, the anti-gay aggression has rotated among differing perpetrators even while the victimized student remained constant. This poses challenges for lawyers seeking to aid students who are harassed in school for being lesbian, gay or bisexual, and may require a new conceptualization of how harassment and violence manifest themselves in school settings.