Footnote 57

We classify under "sexual harassment" any claim of sex discrimination that includes allegations of unwelcome sexual conduct, whether or not it also encompasses complaints of general gender harassment. Pregnancy discrimination claims fall under the heading of gender. In so doing, we do not mean to privilege claims involving sexuality over those that do not. See generally Vicki Schultz, Reconceptualizing Sexual Harassment, 107 Yale L.J. 1683, 1755 (1998) ("We need a new account of hostile work environment harassment that places... gender-based, competence-undermining conduct at its center, one that does not reduce all harassment to sexual objectification or desire.").