In Williams v. New York City Hous. Auth. (61 AD3d 62 [1st Dept. 2009]), the First department concluded that the standard does not apply to the NYCHRL. In Williams that, for purposes of hostile workplace environment claims brought under the NYCHRL, "... the primary issue for a trier of fact in harassment cases, as in other terms and conditions cases, is whether the plaintiff has proven by a preponderance of the evidence that she has been treated less well than other employees because of her gender."