I Introduction

The #MeToo movement went viral on social media when, on 15 October 2017, Alyssa Milano tweeted #MeToo. Her tweet encouraged women who have been sexually abused to post about their experiences on social media with the hashtag to demonstrate the prevalence of sexual harassment. By early November, #MeToo had been retweeted 23 million times from 85 countries.

The current political climate and widespread social media use helped #MeToo promulgate its message and impact numerous industries throughout the United States. Owing to distinct legal and cultural factors, the movement has taken different forms and has had a varying impact across international jurisdictions.

II United States

The Me Too movement was founded by Tarana Burke in 2007 during her work to provide resources to victims of sexual harassment and assault. As mentioned in Section I, the movement went viral on social media on 15 October 2017. In just 24 hours, more than 12 million posts and reactions included #MeToo. One-and-a-half weeks after Milano's tweet, more than 1.7 million tweets across 85 different countries included #MeToo.

Milano's tweet was set against a historic Hollywood backdrop: on 5 October 2017, The New York Times published a story exposing numerous women's sexual assault and harassment allegations against former film producer Harvey Weinstein. The allegations spanned three decades, and came from women across the entire spectrum of film experience. Weinstein announced his leave from the Weinstein Company the same day, and was officially fired three days later from the powerful production company he co-founded. On 10 October 2017, The New Yorker released another bombshell report. Multiple women accused Weinstein of rape and harassment. Four days later, the Academy of Motion Pictures Arts and Sciences removed Weinstein from its ranks. Numerous other distinguished film groups followed suit in the subsequent weeks. In the months that followed, women broke their silence, and accused men working in industries ranging from Hollywood to politics of sexual harassment. The sheer number of allegations could not be ignored, and many men faced swift consequences in their workplace and in the public's opinion. Matt Lauer, Kevin Spacey and Eric Schneiderman are just a handful of the numerous prominent, well-known men who were accused of sexual harassment, and consequently either left or lost their jobs.

The Me Too movement existed for over a decade before it truly gained momentum and resulted in tangible consequences for those accused. The current political climate likely contributed to #MeToo's success. Many Americans feel and act more politically inclined following the results of the 2016 presidential election. An estimated 4.9 million marchers across 673 affiliated marches attended the first planned Women's March the day after President Trump's 2017 inauguration.2 Inspired political action, coupled with social media's influence and widespread use, contributes to an environment that makes #MeToo's success possible.

Still, in the United States, women have been protected from workplace sexual harassment for decades. Title VII of the Civil Rights Act of 1964 prohibits discrimination based on sex. The US Equal Employment Opportunity Commission guidelines and important court decisions such as Meritor Savings Bank v. Vinson in 1986 establish that Title VII prohibits quid pro quo and hostile work environment sexual harassment in the workplace. Employers are strictly liable for a supervisor's harassment that results in a negative employment decision, such as dismissing an employee or failing to hire a potential employee. An employer may only avoid liability for a supervisor creating a hostile work environment if it can show that it reasonably tried to prevent or correct the behaviour, and the employee did not use the employer's preventative or corrective opportunities. Employers are also liable for prohibited harassment by employees who are not supervisors, and non-employees that it controls, if the employer knew or should have known about the harassment and did not take corrective action.3

III Europe

i Italy

In 1991, Italy enacted Law 125/1991 to encourage employers to employ women and to combat the existing discrimination against women in the workplace. Law 125/1991 was amended in May 2005 to implement the EU Equal Treatment Directive. As amended, the law explicitly prohibits direct and indirect discrimination in the workplace, including sexual harassment.4 If employers make an adverse employment decision as a consequence of an employee submitting to or refusing to submit to the unlawful sexual harassment, the employment decision is considered invalid. In addition to other remedies, the employer may be required to pay damages, including psychological damages to the victim (employee).5

Italian-born film actress and director Asia Argento was one of the first women to report that Harvey Weinstein sexually assaulted her. In the United States, the response was swift: three days after the initial New York Times report was published, Weinstein was fired from the company he co-founded.

But the response in Italy was very different. Despite the credibility associated with allegations by over 50 women across more than 30 years against the same powerful Hollywood mogul, Argento's revelation was not well received in her home country. The news and media heavily criticised Argento for her report. An op-ed in Libero, an Italian right-wing newspaper, noted allegations may be borne out of regret for sex that was originally consensual.6 Libero's editor publicly stated Argento should be grateful Weinstein forcibly performed oral sex on her.7 Female Italian public figures were similarly unsympathetic. Selvaggia Lucarelli, a feminist writer, characterised Argento's experience as consensual and said that her 20-year reporting delay was not 'legitimate'.8 These and numerous other public remarks were enough to force Argento to flee Italy to escape the media's toxic atmosphere of victim-blaming and comparisons to prostitution. After 10 women accused Italian film director Fausto Brizzi of molesting them, Warner Brothers suspended all future work with the director. The media, however, overwhelmingly supported the director,9 and few other prominent Italian figures have faced similar consequences during the #MeToo movement.

Indeed, it seems that an unsympathetic Italian response is not unique to Argento's story. In December 2017, the president of Italy's lower house of Parliament, Laura Boldrini, held a women-only conference to draw attention to the fact that Italian citizens often ignore women's reports of sexual harassment. She noted the #MeToo worldwide movement ignited by the Weinstein report has not 'had the same effect' in Italy.10 As to why, she joked 'in our country, there are no harassers'.11 She went on to admit harassment was rampant, but Italy's 'strong prejudice' against women causes them to remain silent.12

Some believe religious education may contribute to Italy's stance towards sexual harassment. Lorella Zanardo, an Italian women's rights activist and author, believes Italy's prejudices towards women are rooted in Catholic education.13 She notes that traditional Catholic education preaches gender roles that include a woman's role as an obedient 'good wife'.14 In the #MeToo context, this rigid gender role may discourage reporting unchaste or taboo acts of sexual harassment.

Italian politics may also be a more recent contributing factor to the prejudices against women in the sexual harassment context. Perhaps one of today's most well-known Italian politicians is Silvio Berlusconi, who served as Prime Minister for nine years, over three terms between 1994 and 2011. While in office, Berlusconi was known for his 'bunga bunga' parties, graphic accounts of which detail women being fondled, kissed and made to grope Berlusconi.15 Berlusconi was acquitted of paying for sex with an underage prostitute at a 'bunga bunga' party after a court found he did not know the woman was underage.16

In addition to his political career, Berlusconi is also a billionaire media mogul and the controlling owner of Mediaset, Italy's largest commercial television broadcaster. Like much of Italian television, Mediaset's channels largely objectify women as silent provocative dancers and otherwise sexual objects.17 Though Berlusconi has not held office since 2011, his political career is currently making a comeback as his six-year ban on political office for a tax fraud conviction in 2012 nears an end. Berlusconi's prominence likely reinforces stereotypes and prejudices against women.

ii France

#MeToo evoked a different reaction in neighbouring France. The French equivalent of the hashtag, #BalanceTonPorc, translates into 'rat out your pig'. The hashtag encouraged French women to use social media to name their abusers and inspired hundreds of thousands of posts. French President Emmanuel Macron's actions stand in stark contrast to Berlusconi's: Macron generally encourages policies promoting gender equality18 and urged revoking Weinstein's Legion of Honor, which he won in 2011.

Still, the conversation sparked in France does not entirely support #MeToo, or the practice of outing one's harasser. Instead, a backlash brought to light a division between feminist theories in France. In January 2018, 100 famous French women, including Catherine Deneuve, penned an open letter published in a daily French newspaper, Le Monde. The letter denounces #MeToo as 'puritanical' and represents a feminist theory born out of the 1960s sexual revolution.19 These feminists believe #MeToo undoes much of the sexual revolution's work of de-censoring sexual desire.20 The #MeToo backlash in France is also likely influenced by a culture that encourages flirtation and seduction.21 The letter also explicitly defends men's right to pester women. Berlusconi described Deneuve's letter as 'blessed words'.22

The divide between the authors and those who support #MeToo is largely generational. Many young women in France believe the days of exalting seduction are over, and the #MeToo movement emboldens women to draw boundaries in the workplace.23 Indeed, disagreeing French feminists wrote letters in response to Deneuve's. Caroline De Haas, the founder of a French women's organisation, responded with a letter co-signed by 30 women, which noted that 'it's not a difference of degrees between flirting and harassment, but a difference in nature'.24 In France, #MeToo sparked a clash between an age-old cultural adoration of seduction, and a modern understanding that seduction in the form of harassment is not welcome.

IV Asia

i Japan

Cultural phenomena unique to Japan created a distinctive reaction to #MeToo there. Saving face, or avoiding embarrassment for oneself and others, is considered a high priority in Japan.25 This cultural value may further deter women from reporting sexual harassment. Indeed, in a May 2018 survey of over 200 large and medium-sized Japanese companies, only 14 per cent of companies surveyed said they received complaints of sexual harassment in the past year.26 A 2015 government survey found only 4 per cent of rape and sexual assault victims reported to the police and more than two-thirds of victims surveyed had not told a single person about the crimes.27 Japanese culture pressures people to 'bear one's hardship'.28 This deters reporting, and may help explain the culture of widespread victim-blaming.

Women's status in the workforce also may help account for under-reporting. Though Japanese women participate in the labour force at a higher rate than US women, their prospects for advancement and overall outcomes are often worse.29 According to OECD data from 2016, just 0.7 per cent of women employed were managers, compared to 3.5 per cent of men employed. For comparison, data from 2013 shows that in the United States, 14.6 per cent of women employed were managers, while 16.9 per cent of men employed were managers. Even more starkly, only 3.4 per cent of seats on boards of the largest publicly listed companies in Japan were held by women in 2016.30 In the United States, that number is 16.4 per cent. Japan ranked 114th out of 144 countries in the World Economic Forum's 2017 gender gap report.31 Perhaps women's low status in the workforce deters them from reporting: an April 2018 online poll of 1,000 working Japanese women found 60 per cent of those who experienced sexual harassment at work 'put up with it' to protect their status in the workplace, and only 24 per cent of women surveyed reported it at work or to someone else.32 Yet companies have not prioritised improving sexual harassment policies: a May 2018 survey found 78 per cent of companies said they had not strengthened sexual harassment policies, and 77 per cent said they were not considering policy changes.33

To combat cultural factors unique to Japan, which result in women drastically under-reporting sexual harassment, #MeToo has taken a new form in the country. In its place, #WeToo encourages unity between victims and supporters. #WeToo was created in the hope of increasing reporting, as well as a feeling of support, solidarity and validation for victims.

Despite the cultural and workplace barriers Japanese women face, #MeToo has had an impact in at least one case in Japan. A female reporter for TV Asahi told a Japanese magazine that Junichi Fukuda, the finance ministry's top bureaucrat, repeatedly sexually harassed her. Fukuda resigned in mid April, though he admitted no wrongdoing. This was the first time in 20 years that a senior official from the finance ministry resigned over misconduct. Still, the immediate reaction to the reporter's accusation was not supportive of her accusation. The reporter took her story to the magazine only after her managers at TV Asahi advised her to remain silent about the harassment. The finance minister initially announced he had no plans to investigate the claims. Later, the ministry urged female reporters to cooperate with fact-finding. This move was criticised as essentially pressuring victims to face their harassers.34

ii India

India's violent and documented history of workplace harassment laws began in 1992. That year, Bhanwari Devi worked as an employee of the Rajasthan government's Women's Development Project. As was required by her government job, Devi reported to the police five upper-caste men's plan to marry off a nine-month-old girl. In response, the men gang raped Devi and beat her husband. Devi reported the rape to the police. This type of rape complaint was very rare in India in 1992, especially against men of a higher caste. Initially, the police did not accept her complaint, but women's groups pressured the police into allowing Devi's complaint. The five men were acquitted three years later. The judgment was appealed and Devi is still awaiting a final verdict. Devi's experience inspired women's groups to file public interest litigation, which resulted in the first set of workplace harassment guidelines, the Vishaka Guidelines, in 1997.

India enacted more biting prohibitions on workplace sexual harassment in 2013. The Sexual Harassment of Women at Workplace Act was similarly enacted in response to a brutal and widely publicised gang rape. Jyoti Singh was 23 years old when she was gang raped on a public bus and left naked on the side of the road. Singh died two weeks later from injuries sustained during the rape. Thousands of Indian citizens protested to demand the government take greater action to ensure women's safety and impose stricter punishments for sexual crimes. The government responded to this demand in December 2013 with the Sexual Harassment of Women at Workplace Act. The Act requires employers to set up a system for reporting and addressing complaints, which may include an internal complaints committee. The committee is required to provide certain types of rectification before beginning its investigation. The Act imposes strict punishments on non-compliant employers: they can be punished with a fine of up to 50,000 rupees. Repeated violations are subject to higher penalties, as well as business delicensing or deregistration.35

As Devi and Singh's stories demonstrate, Indian women face a pervasive threat of sexual harassment everywhere from the public bus to the workplace. Indian feminism has, perhaps out of necessity, focused on issues affecting women such as child marriage, dowry-related violence and even the existential threat of rampant female foeticide.36 As evidenced by the public outcry following Singh's brutal gang rape, Indians also have begun to demand safety for women from sexual assault. Still, #MeToo faces obstacles in India, where many still see women as inferior to men.37 In a common criticism of the movement, many Indians have outright rejected #MeToo as a movement reserved for women privileged enough to be able to demand freedom from sexual harassment in the workplace. This may be a fair criticism, given the causes Indian feminism has traditionally combatted, and the fact that 59 per cent of urban and 64 per cent of rural Indian women do not have internet access.38

#MeToo could become a rallying movement, particularly in Bollywood. In Bollywood, many female actresses find it commonplace to be asked for sexual favours in return for acting roles.39 One anonymous actress was sexually assaulted by a casting agent. When she reported the event to the police, they told her people in the film industry can do whatever they want.40 Actresses that refuse sexual advances face the possibility of retaliation or being blacklisted.41 India's regional film industries are also slowly bringing the industry's abuse into the public eye. Sri Reddy, a 'Tollywood' actress, staged a nude protest in April 2018. Videos of Reddy's protest spread over the internet and incited comments that she was merely attempting to further her career.42 Radhika Apte, one of the few Bollywood stars to speak out about her experiences refusing producers' sexual advances, explains one barrier to Bollywood catching onto the #MeToo movement is the system of earning film roles in Bollywood. Unlike in Hollywood, where theatre and acting education is heavily valued, earning roles in Bollywood is based on professional contacts, personal conduct and appearance.43 Bollywood's #MeToo movement may be yet to come, given women's reluctance to report abuses.

V Egypt

Sexual abuse in Egypt is also common, as indicated by a 2017 UN poll. The poll ranked Cairo as the most dangerous megacity for women based on factors including how well-protected women are from sexual assault.44 Until 2014, Egyptian law did not define or criminalise sexual harassment. A 2014 law punishes sexual harassment with fines up to 5,000 Egyptian pounds and jail sentences between six months and five years. Harassers who hold a position of power over victims, including in the workplace, face longer sentences.45

One potential obstacle to #MeToo's influence in Egypt is the police. Women may feel uncomfortable reporting sexual harassment to male police officers, and there is a dearth of female officers in Egypt.46 In 2008, Noha al-Ostaz dragged her assailant to a police station, but the police refused to file a complaint until al-Ostaz's father arrived. Harassment by a policeman inspired Amal Fathy to post a video detailing the harassment and discussing the government's failure to protect women. Fathy was charged with crimes including insulting Egypt.47 Perhaps in response to this issue, Egypt's Ministry of the Interior deployed female police officers to crowded areas during the Eid al-Fitr holiday specifically to combat sexual violence against women.

Without simplifying the issue to merely a product of religion, #MeToo has impacted Egyptian society's practice of religion. Mona Eltahawy is an Egyptian-American activist and journalist. When she was 15 years old, she journeyed to Mecca, Saudi Arabia for the holy Islamic pilgrimage called hajj. During a sacred religious moment and while in a hijab, Eltahawy was groped by a stranger. In response to a Pakistani woman's post about a similar experience at hajj, Eltahawy posted her story on Twitter using #MeToo. Her tweet inspired hundreds of posts sharing similar stories. Eltahawy then posted #MosqueMeToo to encourage more women to share their stories from the Muslim world and break 'taboo' around sexual harassment 'in sacred spaces'.48 Similar stories of sexual assault in the Muslim world and during holy Islamic exercises are shockingly common.49 Many Muslim women are hesitant to report abuse because they do not want to fuel Islamophobia.50 Others may fear a conservative backlash that could result in men and women being separated while praying at holy sites.51 #MeToo may face obstacles in societies where religious factors increase women's reluctance to report abuse.

VI Mexico

Just as actresses in the United States and, albeit to a much lesser extent India, are leading the #MeToo movement in their countries, several reports from the Mexican entertainment industry sparked the #MeToo conversation in Mexico. In February 2018, well-known Mexican actress Karla Souza reported she was pressured sexually and later raped by an unnamed Mexican director. Though Souza did not name Gustavo Loza in her report, a major Mexican media company, Televisa, cut the director from its business the next day. Unlike Televisa's action, the Mexican media did not support Souza or others who have similarly reported abuse.52 TV host Horacio Villalobos called the women 'irresponsible . . . to go on TV and refuse to name names and make false accusations'.53 Just as in Italy, the media's reaction was overwhelmingly critical of women's decisions to report abuse. And just as in India, some in the Mexican entertainment industry have experienced widespread sexual harassment in their industry for decades. Sabina Berman reports that she was molested by the president of the Mexican Writer's Guild for 10 years beginning when she was 19. Berman made these claims publicly on CNN en Español, where she also accused a casting agency of misconduct involving underage girls. After the agency vehemently denied the accusation, Berman withdrew her allegation against the agency and apologised for her false accusation.54

But the media response was not completely one-sided. Security analyst Alejandro Hope published an article with his explanation of why women choose not to report abuse in his weekly op-ed column.55 Hope cited numerous factors, including that women who report do not receive judicious outcomes, and they are forced to relive their abuse. Hope also noted that women may be blamed for not knowing men 'think with their genitals' and for misinterpreting flattery and flirting for harassment.56 Women utilised the #YoNoDenuncioPorque to explain for themselves why they did not report abuse.

As Hope's cited reasons may indicate, the Mexican culture exalting 'machismo' may affect #MeToo's impact in the country. Machismo, or male entitlement, is widespread and deeply rooted in Mexico's culture and society.57 Machismo culture may help account for rife gender-based violence against women in Mexico: between 2007 and 2015, the femicide rate doubled from 1,086 per year to 2,555 per year.58 Rafael Vallejo Gil, a labour and employment partner at the Mexican law firm Gonzalez Calvillo, agrees that deep-seeded cultural machismo fosters workplace sexual harassment.59 Gil believes the Mexican culture of individualistically dealing with one's own problems further deters women from reporting sexual harassment.60 These cultural values are so deeply ingrained that Gil estimates it will take the Mexican government's concerted effort and an entire generation to eradicate these values.61 Until then, #MeToo has moved Mexican professionals to consider other countries' efforts to increase reporting as examples for their companies. Gil has also noticed an increase in companies requiring sexual harassment training. Yet he finds employees receive the training differently based on whether they work for a multinational company or a local company: those working in multinational companies are more likely to view the training as evidence of the companies' social responsibility and appreciate the training; whereas those working for more local companies may view training as worthless, and as the company's shallow attempt to maintain a positive image.62

VII Advice to multinational employers

Sexual harassment cases have arisen out of workplace conduct for decades. #MeToo has had a global impact on how these cases are perceived and addressed. Employers must concentrate on protecting their brand and reputation, which has become increasingly challenging in the social media era. When addressing individual sexual harassment complaints and conducting investigations, it is imperative that multinational companies understand not just the legal differences, but also the cultural nuances in the jurisdictions in which they operate.


Footnotes

1 Erika C Collins is a partner at Proskauer Rose LLP.

2 Sister Marches, Women's March, https://www.womensmarch.com/sisters (last visited 17 July 2018).

3 Harassment, U.S. Equal Employment Opportunity Commission, https://www.eeoc.gov/laws/types/harassment.cfm (last visited 17 July 2018).

4 Piergiovanni Mandruzzato and Sara Bittolo, International Labor and Employment Laws 6–115 – 6–116 (William L. Keller et. al. eds., 4th ed. 2015).

5 id.

6 See Sylvia Poggioli, In Italy, #MeToo Falters Amid Public Scorn, NPR (18 January 2018),
https://www.npr.org/sections/parallels/2018/01/18/578562334/in-italy-metoo-falters-amid-public-scorn.

7 Kenzie Bryant, Asia Argento Escapes to Germany After Onslaught of Victim-Blaming in Her Native Italy, Vanity Fair (20 October 2017), https://www.vanityfair.com/style/2017/10/asia-argento-harvey-weinstein-italian-backlash.

8 id.

9 See Poggioli, note 6.

10 See Jason Horowitz, In Italy, #MeToo Is More Like 'Meh', The New York Times (16 December 2017),
https://www.nytimes.com/2017/12/16/world/europe/italy-sexual-harassment.html.

11 id.

12 id.

13 See Poggioli, note 6.

14 See Poggioli, note 6.

15 See Jason Silverstein, Former Italian Prime Minister Silvio Berlusconi had women kiss penis statue, sing his name at 'bunga bunga' sex parties: report, NY Daily News (20 August 2015), http://www.nydailynews.com/news/world/book-new-details-silvio-berlusconi-bunga-bunga-article-1.2331839.

16 See Agence France-Presse, Silvio Berlusconi's 'bunga bunga' acquittal upheld by high court, The Guardian (20 March 2015), https://www.theguardian.com/world/2015/mar/10/silvio-berlusconis-bunga-bunga-aquittal-upheld-by-high-court.

17 See Poggioli, note 6; Elisabetta Povoledo, Women Take On Sexist Image in Italian Media, The New York Times (17 June 2009), https://www.nytimes.com/2009/06/18/arts/18iht-women.html.

18 See Odette Chalaby, Macron's fight for gender equality: the policies behind his 'grand cause', apolitical (13 March 2018), https://apolitical.co/solution_article/macrons-fight-for-gender-equality-the-policies-behind-his-grand-cause/.

19 Agence France-Presse, Catherine Deneuve says men should be 'free to hit on' women, The Guardian (9 January 2018), https://www.theguardian.com/film/2018/jan/09/catherine-deneuve-men-should-be-free-hit-on-women-harvey-weinstein-scandal.

20 id.

21 See Elena Berton, Why the French are balking at the #MeToo movement, USA Today (7 February 2018, 5:42pm), https://www.usatoday.com/story/news/world/2018/02/07/why-french-balking-metoo-movement/303648002/.

22 Peter White, Silvio Berlusconi Backs Catherine Deneuve Over Controversial #MeToo Comments, DEADLINE (12 January 2018), https://deadline.com/2018/01/silvio-berlusconi-backs-catherine-deneuve-over-controversial-metoo-comments-1202241692/.

23 See Saphora Smith, France in the age of #MeToo grapples with seduction, harassment, NBC News (29 January 2018), https://www.nbcnews.com/news/world/france-age-metoo-grapples-seduction-harassment-n840501.

24 Nancy Tartaglione, French Feminists Blast Catherine Deneuve & Co Over #MeToo Slam, DEADLINE (10 January 2018), https://deadline.com/2018/01/catherine-deneuve-metoo-criticism-backlash-france-1202239864/.

25 See Rochelle Kopp, Saving Face: A Little Discretion Can Go a Long Way in Japan, Japan Intercultural Consulting (23 March 2010), http://www.japanintercultural.com/en/news/default.aspx?newsID=59.

26 Sexual harassment policies unchanged at most firms in Japan, despite growing awareness amid global Me Too movement: poll, The Japan Times (25 May 2018), https://www.japantimes.co.jp/news/2018/05/25/national/social-issues/japan-inc-awareness-harassment-rise-little-movement-toward-improvement-reuters-poll/#.WyhlYaYqQy-.

27 Kurumi Mori and Shoko Oda, #MeToo Becomes #WeToo in Victim-Blaming Japan, Bloomberg (9 May 2018, 4pm), https://www.bloomberg.com/news/articles/2018-05-09/-metoo-becomes-wetoo-in-victim-blaming-japan.

28 #MeToo Japan: What happened when women broke their silence, BBC (25 April 2018), https://www.bbc.com/news/world-asia-43721227.

29 Jay Shambaugh, Ryan Nunn and Becca Portman, Lessons from the rise of women's labor force participation in Japan, Brookings (1 November 2017), https://www.brookings.edu/research/lessons-from-the-rise-of-womens-labor-force-participation-in-japan/.

30 Organization for Economic Co-operation and Development, Employment: Female share of seats on boards of the largest publicly listed companies, https://stats.oecd.org/index.aspx?queryid=54753 (last visited 28 June 2018).

31 id.

32 See Kurumi Mori, note 27.

33 Sexual harassment policies, note 26.

34 #MeToo Japan: What happened when women broke their silence, BBC (25 April 2018), https://www.bbc.com/news/world-asia-43721227.

35 See The Protection of Women Against Sexual Harassment at Work Place Bill (2010), http://www.prsindia.org/billtrack/the-protection-of-women-against-sexual-harassment-at-work-place-bill-2010-1402/.

36 See Alka Kurian, #MeToo is riding a new wave of feminism in India, The Conversation (1 February 2018), http://theconversation.com/metoo-is-riding-a-new-wave-of-feminism-in-india-89842.

38 Ananya Bhattacharya, In India, the internet is a place for cityfolk and men, Quartz (21 February 2018), https://qz.com/1211218/in-india-the-internet-is-a-place-for-urban-dwellers-men-and-youngsters/.

39 See #MeToo: Why sexual harassment is a reality in Bollywood, BBC (28 April 2018), https://www.bbc.com/news/world-asia-india-43881129.

40 id.

41 id.

42 See Jeffrey Gettleman, Indian Actress Stages a Topless #MeToo Protest, The New York Times (8 April 2018), https://www.nytimes.com/2018/04/08/world/asia/india-actress-topless-metoo.html.

43 See #MeToo: Why sexual harassment is a reality in Bollywood, note 39.

44 EXCLUSIVE – Cairo named most dangerous megacity for women; London best – poll, Reuters (15 October 2017), https://af.reuters.com/article/africaTech/idAFL8N1L74J3.

45 See Egypt brings in new sexual harassment laws, BBC News (5 June 2014), https://www.bbc.com/news/world-middle-east-27726849.

46 See Azza Solimon, How #MeToo and #TimesUp Are Helping Egyptian Women Break the Silence Around Sexual Violence, TIME (17 May 2018), http://time.com/5280726/how-metoo-and-timesup-are-
helping-egyptian-women-break-the-silence-around-sexual-violence/; Patrick Kingsley, Egypt criminalises sexual harassment for first time, The Guardian (6 June 2014), https://www.theguardian.com/world/2014/jun/06/egypt-criminalises-sexual-harassment.

47 See Susannah Cullinane, Egyptian activist detained over social media video post criticizing government, CNN (11 May 2018, 10:54pm), https://www.cnn.com/2018/05/11/middleeast/egypt-amal-fathy-activist-detained/index.html.

48 Malaka Gharib, #MosqueMeToo Gives Muslim Women A Voice About Sexual Misconduct at Mecca, NPR (26 February 2018), https://www.npr.org/sections/goatsandsoda/2018/02/26/588855132/-mosquemetoo-gives-muslim-women-a-voice-about-sexual-misconduct-at-mecca.

49 id.

50 id.

51 id.

52 Carrie Kahn, Mexico And The #MeToo Movement, NPR (21 March 2018, 8:35am), https://www.npr.org/2018/03/21/595516892/mexico-and-the-metoo-movement.

53 id.

54 id.

55 See Alejandro Hope, Ellas no denuncian [They do not report], El Universal (26 February 2018, 2:06pm), http://www.eluniversal.com.mx/columna/alejandro-hope/nacion/ellas-no-denuncian; Carrie Kahn, Mexico's #MeToo Faces Backlash After Celebrities Air Accusations of Rape and Assault, NPR (27 March 2018, 9:55am), https://www.npr.org/sections/parallels/2018/03/27/596662573/mexicos-metoo-faces-backlash-after-celebrities-air-accusations-of-rape-and-assau.

56 See Hope, note 55.

57 See Paulina Villegas, Where Machismo Is Entrenched, Focus Moves to the Trenches, The New York Times (23 April 2017), https://www.nytimes.com/2017/04/23/world/americas/where-machismo-is-entrenched-focus-moves-to-the-trenches.html.

58 id.

59 Telephone Interview with Rafael Vallejo Gil, Partner, Gonzalez Calvillo (6 July 2018).

60 id.

61 id.

62 id.