George McGinest, an African-American employee of GTE Service Corporation (“GTE”), sued GTE under Title VII for creation of a racially hostile work environment, failure to promote due to racial discrimination, and failure to promote due to retaliation. McGinest claims that GTE created a racially hostile work environment based both upon its perpetration of and its failure to adequately respond to a large number of incidents that occurred over a fifteen year period. In support of his hostile work environment claim, McGi-nest alleges that he was placed in dangerous working conditions because of his race, prevented from collecting bonus pay available to non-African American coworkers, forced to endure racial taunts and insults by supervisors and coworkers, and subjected to racist graffiti in GTE’s bathrooms and on switch boxes. Additionally, McGi-nest claims that he was denied a promotion in late 1998 due to his race and in retaliation for filing an EEOC complaint; GTE responds that it was unable to promote him due to a hiring freeze.
The district court granted summary judgment to GTE. The court found that the incidents comprising the hostile work *1107environment claim were sporadic, and for the most part adequately remedied. Moreover, it found that McGinest was unable to produce sufficient evidence that GTE’s stated reason for failing to promote him was a pretext.
We reverse the district court’s dismissal of the hostile environment and disparate treatment claims. The district court resolved numerous factual questions in favor of GTE, failed to distinguish between supervisors and coworkers in evaluating GTE’s liability, and did not consider fully the cumulative impact of the events that occurred. Because McGinest has established genuine material issues of fact regarding his hostile work environment claim, as well as on the question of whether the denial of the promotion was prompted by a discriminatory motive, these claims must be remanded. However, McGinest has failed to establish a prima facie case of retaliation, and so we affirm the district court’s dismissal of this claim.
I.
BACKGROUND
George McGinest is an African-American employee of GTE, a telecommunications company.1 He has worked for GTE for 23 years, and has continued to do so during the course of this litigation. McGi-nest was initially hired as a lineman, and subsequently has worked as an outside plant construction worker and relief supervisor. At the GTE facilities at which McGinest has worked, he has been one of few African-American employees. Because this case was decided on summary judgment, we evaluate the facts in the light most favorable to McGinest, the non-moving party. Lam v. Univ. of Hawaii, 40 F.3d 1551, 1555 n. 2 (9th Cir.1994).
A. Hostile Work Environment
McGinest describes a number of events and practices, which he alleges cumulatively created a hostile work environment. These events fall roughly into two categories: some involved discriminatory treatment through concrete actions, while others involved written and oral derogatory statements.
1. Concrete Actions
Events Involving Supervisor Jim Noson
Jim Noson supervised McGinest for five or six years, at a facility in Long Beach, ending in the early 1990s. During this time, Noson engaged in numerous acts of racial harassment directed toward McGi-nest. Although the majority of these incidents were not accompanied by explicit racial comments, McGinest testified at his deposition that Noson’s behavior and “any comment that he made was because of my race.” According to McGinest, Noson forced McGinest to work under dangerous conditions or without proper equipment, and subjected him to obscene and demeaning language. When McGinest was responsible for a project, Noson would not provide him with sufficient crew members to safely perform the job. Noson also indicated his desire to fire McGinest on several occasions, and specifically stated that he wished to provoke McGinest into fighting with another worker so that he could fire both of them. On one occasion, Noson noted that McGinest was wearing a gold chain, and commented “only drug dealers can afford nice gold chains.”
*1108Noson’s abusive conduct was also aimed at Matt Ketchum, a white coworker and friend of McGinest. McGinest testified that although Ketchum “received the blunt of the problem too, it still was directed to me because of my race .... 90 percent of time, if he wasn’t [ ] with me, he wouldn’t receive the same bashing.”
Any time that McGinest had a problem with Noson he gave notes complaining about Noson’s conduct to his supervisor, Hank Bisnar, and complained in person. Because McGinest’s complaints were not successful in remedying the problem, McGinest ultimately filed an internal discrimination complaint noting twelve incidents where Noson had treated him in a discriminatory manner. GTE claims that it conducted an internal investigation, finding Noson’s comments to be merely “shoptalk,” but requiring Noson to apologize to McGinest. However, McGinest states that he never received a response to his complaint.
Overtime for Relief Supervisors
From 1995 to 1997, non-African-American relief supervisors received overtime pay when they arrived early to set up for their shift. On some occasions, relief supervisors were permitted to claim an entire hour of overtime when they arrived just five minutes early to set up for their shift. GTE acknowledges that until the arrival of the new manager, Mike Begg, there was an unwritten rule that relief supervisors got an hour of overtime for each shift. McGinest testified that even after Begg’s arrival, some supervisors continued to get “bonus” overtime pay, however, McGinest’s supervisor, Don Roberts, refused to allow him to claim any of the overtime that he actually worked when he was a relief supervisor. McGinest challenged this differential treatment for several paychecks, submitting timesheets that reflected the overtime that he worked, only to have the overtime removed by Roberts. McGinest complained repeatedly about this treatment.
Coworkers’ Refusal to Obey When McGi-nest Was Relief Supervisor
In 1995, McGinest moved from the Long Beach facility to Huntington Beach. Upon his arrival, he had difficulties with coworkers who refused to work under his supervision when he was the relief supervisor. On one occasion, several workers refused to work for him in carrying out a job that was extremely dirty and undesirable. Brian Brand, a white coworker, testified that they also refused to work for him on the same occasion. McGinest did not complain to management about this incident.
Maintenance of Vehicles
In March of 1997 McGinest became concerned that one of the tires on his company vehicle was wearing out. Since ninety percent of his driving time was on the freeway, he was concerned for his safety. He sent a request in writing to the garage to have the tire replaced, but the garage mechanic replied that there was nothing wrong with the tire. He also informed his supervisor, Don Roberts, about the need to replace the tire, but Roberts said that “the company wouldn’t spend any money on any tires.” After McGinest’s request for repair was denied, he showed the tire to another supervisor, who agreed that the tire looked bald.
Two to three weeks after these events, the tire blew out while McGinest was driving the vehicle and he crashed into a wall. McGinest was treated for injuries at the hospital. His leg was injured and he had to wear a neck brace.
McGinest testified that almost everyone was driving around in vehicles with better tires. He explained that when white employees “want[ ] something fixed, they get it,” and cited an example of a white em*1109ployee who had requested new tires around the same time that McGinest had, but who had obtained them. Another coworker, Brand, agreed that the garage mechanic and the foreman seemed to have a particular problem with three black employees, one of whom was McGinest, noting that they “continuously treated George [McGinest] in a de[]meaning and[condescending] manner in my presence.” Brand testified that “[f]or the most part they seemed to be pretty good with myself, and [others] ... we happen to be white, it could have been racial. It could have been just personality.”
2. Racial Slurs and Derogatory Comments
Derogatory Statement by Coordinator Tom Hughes
In May 1996, Tom Hughes called McGi-nest “stupid nigger” to his face, an epithet that was overheard by Brand. Hughes had referred to McGinest on other occasions as “stupid” and “sparrow brain,” and had told McGinest, “you should stay in Long Beach where you belong, with your kind.”
McGinest did not report the May 1996 incident immediately because he was so enraged that he had to leave the building. The next day, McGinest reported to his immediate supervisor, Gary Deason, that Hughes was “always calling me a name.” However, he did not pursue a formal complaint with the management because of his conviction that it would be futile, “because I went to management with several different things and nothing changed, over and over again.”
Rather, McGinest filed a complaint with the EEOC. Upon receiving a call from the EEOC in July 1997, human resources manager Jeff Nakamura began an investigation of the incident. Nakamura found Hughes’s denial that this comment occurred plausible. Based on this belief and the EEOC’s refusal to provide him with the name of the witness, Nakamura did not pursue the investigation. Nakamura testified that he waited two years to reini-tiate the investigation “because in the meantime I thought the agency would be cooperative by sharing with me the name of the witness so I could do a thorough investigation.” Once Nakamura did reopen the investigation, he learned the name of the witness by interviewing several employees. After Brand, the witness, confirmed that the epithet had been used, Nakamura determined that disciplinary action should be taken despite Hughes’s continued denial. Hughes was counseled against using such words, shown a video on sexual harassment, and received a disciplinary memo.2 There is no allegation that Hughes engaged in any further objectionable conduct following this discipline.
Comment by Supervisor Ledbetter
McGinest and Brand testified that in January 1997 Paul Ledbetter, a supervisor, was frustrated that McGinest and his crew were not able to perform a work *1110assignment immediately. They quoted him as saying, “The other colored guy who used to work here would jump when I said it. It is a damn shame how it’s gone downhill.” McGinest reported this incident to management. GTE claims that Ledbetter no longer worked at GTE in 1997.
Comments by Coworkers
On one occasion, coworker Alex Tal-madge said, referring to McGinest, “I’ll retire before I work for a Black man.” Another coworker, Jim Frick, said of McGinest, “I refuse to work for that dumb son of a bitch.” McGinest complained about these incidents to Roberts and Begg.
In 1996 and 1997, McGinest’s coworker Daniel DeLeon called Ketchum “Aunt Je-mima” numerous times in the presence of McGinest. DeLeon also referred to McGi-nest as Ketchum’s “mammy” on a number of occasions. McGinest and a black coworker note that the phrase “Aunt Jemi-ma” is a racial insult, connoting laziness and servitude. Although Ketchum is white, McGinest explained that the comment was intended to irk McGinest, and was directed at Ketchum because he is friends with black employees.
McGinest requested that DeLeon not use this phrase because he found it racist, but was told “fuck you” in response. McGinest reported the comment both to manager Mike Begg and to supervisor Roberts, who supervised McGinest and DeLeon, but was unaware if any disciplinary action was taken. Human resources manager Nakamura was apparently unaware of this incident until the phone call from the EEOC representative. Following the call, Nakamura questioned De-Leon. DeLeon claimed that he did not intend “Aunt Jemima” as a racial insult, but rather as a teasing nickname referring to a commercial that emphasized the slowness with which the syrup poured out of the bottle. Ketchum also apparently had a nickname for DeLeon, “Biscuit.” Naka-mura testified that he found DeLeon’s explanation plausible, but nonetheless instructed DeLeon to stop using the phrase.3 There is no allegation that DeLeon continued to use the phrase subsequently.
Racist Graffiti
McGinest saw racist graffiti on the walls of the men’s restroom and in the stalls on multiple occasions. This graffiti included the word “nigger,” sometimes altered to “digger,” and the phrase “white is right.” Other coworkers testified to seeing the phrase “PONTIAC,” meaning “poor old nigger thinks it’s a Cadillac,”4 and, in December 2000, “nigger go home.” Although managers used the same restrooms, the graffiti was not painted over when it appeared and no public action of disapproval was taken.
Similar racist graffiti, particularly the word “nigger,” also was present in GTE switch boxes and in the blockhouse and garage. A coworker noted that one year during Black History Month the word “Black” was crossed out on a poster and “nigger” was written in its place. The defaced poster displayed this epithet until *1111the coworker finally removed it three weeks later.
McGinest only mentioned this graffiti to management on one occasion, around April 1998. On this occasion, McGinest and a coworker reported to A1 Valle that the word “nigger” had appeared in the bathroom, and Valle promptly spray-painted over it. Later, when supervisor Roberts learned about the incident, he said, “Oh well, I guess I’ll have to write it again,” and then added, “Ah, why can’t we all just get along,” in reference to a statement made by Rodney King after being beaten by Los Angeles police officers. Roberts may not have been aware of the precise nature of the graffiti at the time of these comments, as there is testimony that he was merely told that it was condescending.
Following this event McGinest “basically stopped using this bathroom ... because I am offended and disgusted with seeing the “N” word written in the bathroom — -I would get upset if I were to see it written.” The word “nigger” and other racist graffiti have continued to appear in the bathroom since this incident.
Antidiscrimination Policy
Although GTE claims that it has a “zero tolerance” policy fOr discriminatory conduct, its written policy, which appears to have been adopted in 1997, says nothing about zero tolerance or about any ramifications for such conduct. Nor does the written policy detail what steps an employee should follow if the employee feels she or he has been subjected to discriminatory conduct, stating only, “If you have questions concerning equal employment opportunity, discrimination, or affirmative action, discuss them with your supervisor or human resources representative.”
B. Failure to Promote
In September 1998, GTE had a vacancy in the position of Outside Plant Construction Installer Supervisor. McGinest applied for this position, which would have been a promotion. He passed the qualifying exam and was interviewed for the position by Begg in October 1998.
According to GTE, McGinest was selected for the position, but when Begg contacted the human resources department to obtain salary authorization he was informed by Casey Larson that there was a salary/hiring freeze in place. Nakamura testified that the salary freeze was due to GTE’s financial difficulties. Consequently, another employee, John Phalen, was moved laterally into the position.
However, GTE was unable to produce any documentation verifying that there was a salary freeze, and Phalen himself testified that he was unaware that there was a freeze, despite the fact that it was allegedly the reason for his transfer. GTE claims that it is common for salary freezes to be implemented without written notification. The record does not reflect how large an operation GTE was at this time, but at least 175 individuals were employed in the three yards supervised by Begg.
The decision not to promote McGinest occurred approximately a year and a half after McGinest filed his EEOC complaint. McGinest notes that African Americans are underrepresented at GTE, particularly in supervisory positions, and claims that it is difficult for African Americans to advance. In the Huntington Beach yard, where McGinest worked, five or six out of 70 employees were African American, and none were supervisors.
McGinest initially filed a complaint with the EEOC on June 3, 1997. After conducting an investigation, the EEOC determined that the evidence supported a finding that “respondent acted in violation of Title VII of the Civil Rights Act of 1964.” McGinest filed an additional complaint re*1112garding the failure to promote. After the EEOC issued a Right to Sue notice, McGi-nest sued GTE and supervisor Mike Begg. The district court granted summary judgment to the defendants as to all claims. McGinest timely appealed the judgment for GTE, but did not appeal the district court’s dismissal of his claim against Begg.
II.
DISCUSSION
McGinest alleges that GTE’s actions violated his right to be free from invidious discrimination in the workplace. He raises three separate Title VII claims: 1) creation of a racially hostile work environment; 2) failure to promote on account of race; and 3) failure to promote on account of retaliation. We review de novo the district court’s grant of a motion for summary judgment. Schnidrig v. Columbia Mach, Inc., 80 F.3d 1406, 1408 (9th Cir.1996).
In evaluating motions for summary judgment in the context of employment discrimination, we have emphasized the importance of zealously guarding an employee’s right to a full trial, since discrimination claims are frequently difficult to prove without a full airing of the evidence and an opportunity to evaluate the credibility of the witnesses. See, e.g., Schnidrig, 80 F.3d at 1410-11; Lam, 40 F.3d at 1563; Sischo-Nownejad v. Merced Community College Dist., 934 F.2d 1104, 1111 (9th Cir.1991). As the Supreme Court has stated, “The real social impact of workplace behavior often depends on a constellation of surrounding circumstances, expectations, and relationships which are not fully captured by a simple recitation of the words used or the physical acts performed.” Oncale v. Sundowner Offshore Serv., Inc., 523 U.S. 75, 81-82, 118 S.Ct. 998, 140 L.Ed.2d 201 (1998). As a result, when a court too readily grants summary judgment, it runs the risk of providing a protective shield for discriminatory behavior that our society has determined must be extirpated.
III.
HOSTILE WORK ENVIRONMENT
Under Title VII of the Civil Rights Act of 1964, it is “an unlawful employment practice for an employer ... to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race.” 42 U.S.C. § 2000e-2(a)(1) (2003). This prohibition encompasses the creation of a hostile work environment, which violates Title VII’s guarantee of “the right to work in an environment free from discriminatory intimidation, ridicule, and insult.” Meritor Sav. Bank, FSB v. Vinson, 477 U.S. 57, 65, 106 S.Ct. 2399, 91 L.Ed.2d 49 (1986). “Courts have long recognized that a workplace in which racial hostility is pervasive constitutes a form of discrimination.” Woods v. Graphic Communications, 925 F.2d 1195, 1200 (9th Cir.1991).
In order to survive summary judgment, McGinest must show the existence of a genuine factual dispute as to 1) whether a reasonable African-American man would find the workplace so objectively and subjectively racially hostile as to create an abusive working environment; and 2) whether GTE failed to take adequate remedial and disciplinary action. Steiner v. Showboat Operating Co., 25 F.3d 1459, 1462-63 (9th Cir.1994); see also Faragher v. City of Boca Raton, 524 U.S. 775, 787, 118 S.Ct. 2275, 141 L.Ed.2d 662 (1998).
A. Severe or Pervasive Hostile Environment
In determining if an environment is so hostile as to violate Title VII, we *1113consider whether, in light of “all the circumstances,” Nichols v. Azteca Rest. Enter., 256 F.3d 864, 872 (9th Cir.2001), the harassment is “sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.” Meritor, 477 U.S. at 67, 106 S.Ct. 2399 (internal brackets and quotation marks removed). The Supreme Court has followed a “middle path” with regard to the level of hostility or abuse necessary to establish a hostile work environment. Harris v. Forklift Sys., Inc., 510 U.S. 17, 21, 114 S.Ct. 367, 126 L.Ed.2d 295 (1993). Simply causing an employee offense based on an isolated comment is not sufficient to create actionable harassment under Title VII. Id. However, the harassment need not cause diagnosed psychological injury. Id. at 22, 114 S.Ct. 367. It is enough “if such hostile conduct pollutes the victim’s workplace, making it more difficult for her to do her job, to take pride in her work, and to desire to stay on in her position.” Steiner, 25 F.3d at 1463.
A plaintiff must show that the work environment was both subjectively and objectively hostile. Nichols, 256 F.3d at 871-72. Subjective hostility is clearly established in the instant case through McGinest’s unrebutted testimony and his complaints to supervisors and to the EEOC. Id. at 873.
In evaluating the objective hostility of a work environment, the factors to be considered include the “frequency of discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.” Nichols, 256 F.3d at 872 (quoting Harris v. Forklift Sys., 510 U.S. at 23, 114 S.Ct. 367). “The required level of severity or seriousness varies inversely with the pervasiveness or frequency of the conduct.” Id. (internal quotation marks omitted). Considering the facts in the light most favorable to McGinest,5 it is clear that the *1114incidents described are sufficient to survive a motion for summary judgment. According to McGinest, he was involved in a serious automobile accident because, due to his race, both his supervisor and garage personnel were unwilling to ensure that his vehicle received necessary maintenance. He was forced to work in dangerous situations and barraged with insults and abuse by, among others, Supervisor Noson.6 Over a two-year period, he was prevented from collecting overtime pay that he worked.7 McGinest’s ability to *1115perform his job was directly affected by the refusal of his coworkers to work under his direction on occasion.
Additionally, McGinest was subjected to extreme racial insults, as well as more subtle taunts, by supervisors and coworkers. Racist graffiti such as “nigger” and “white is right” regularly appeared in the bathroom and on equipment, and on one occasion a management-level employee called McGinest “stupid nigger” to his face. Although it is clear that “[n]ot every insult or harassing comment will constitute a hostile work environment,” “[repeated derogatory or humiliating statements ... can constitute a hostile work environment.” Ray v. Henderson, 217 F.3d 1234, 1245 (9th Cir.2000).
In evaluating the significance of the statements in question, we consider the objective hostility of the workplace from the perspective of the plaintiff. Nichols, 256 F.3d at 872; Ellison v. Brady, 924 F.2d 872, 878-79 (9th Cir.1991). In Ellison, in the context of sexual harassment, we evaluated objective hostility from the perspective of a reasonable woman. As the Supreme Court has noted, “Hostile work environment claims based on racial harassment are reviewed under the same standard as those based on sexual harassment.” Nat’l R.R. Passenger Corp. v. Morgan, 536 U.S. at 116 n. 10, 122 S.Ct. 2061. We now state explicitly what was clear from our holding in Ellison, that allegations of a racially hostile workplace must be assessed from the perspective of a reasonable person belonging to the racial or ethnic group of the plaintiff.8
In Ellison we noted that “[a] complete understanding of the victim’s view requires, among other things, an analysis of the different perspectives of men and women.” 924 F.2d at 878. We explained:
because women are disproportionately victims of rape and sexual assault, women have a stronger incentive to be concerned with sexual behavior. Women who are victims of mild forms of sexual harassment may understandably worry whether a harasser’s conduct is merely a prelude to violent sexual assault. Men, who are rarely victims of sexual assault, may view sexual conduct in a vacuum without a full appreciation of the social setting or the underlying threat of violence that a woman may perceive.
Id. at 879 (citations omitted). Our analysis of the importance of interpreting gender discrimination from the perspective of a reasonable woman reverberates powerfully in the context of racial harassment. See Stingley v. Arizona, 796 F.Supp. 424, 428-29 (D.Ariz.1992) (noting that “Ellison’s reasoning may be applied seamlessly to *1116racist environment claims,” and implementing a “reasonable person of the same gender and race or color” standard).
Racially motivated comments or actions may appear innocent or only mildly offensive to one who is not a member of the targeted group, but in reality be intolerably abusive or threatening when understood from the perspective of a plaintiff who is a member of the targeted group. “The omnipresence of race-based attitudes and experiences in the lives of black Americans [may cause] even nonviolent events to be interpreted as degrading, threatening, and offensive.” Harris v. Int’l Paper Co., 765 F.Supp. 1509, 1516 (D.Me.1991) (noting that “instances of racial violence or threatened violence which might appear to white observers as mere ‘pranks’ are, to black observers, evidence of threatening, pervasive attitudes”), vacated in part on other grounds, 765 F.Supp. 1529 (D.Me.1991); see also id. (discussing “racial jokes, comments or nonviolent conduct which white observers are ... more likely to dismiss as nonthreatening isolated incidents”); Dickerson v. State of New Jersey Dep’t of Human Serv., 767 F.Supp. 605, 616 (D.N.J.1991) (“The mere mention of the KKK invokes a long and violent history sufficient to detrimentally affect any reasonable person of the same race as the plaintiff.”) (emphasis in original). “Title VII tolerates no racial discrimination, subtle or otherwise.” McDonnell Douglas Corp. v. Green, 411 U.S. 792, 801, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). By considering both the existence and the severity of discrimination from the perspective of a reasonable person of the plaintiffs race, we recognize forms of discrimination that are real and hurtful, and yet may be overlooked if considered solely from the perspective of an adjudicator belonging to a different group than the plaintiff.
It is beyond question that the use of the word “nigger” is highly offensive and demeaning, evoking a history of racial violence, brutality, and subordination. This word is “perhaps the most offensive and inflammatory racial slur in English, ... a word expressive of racial hatred and bigotry.” Swinton v. Potomac Corp., 270 F.3d 794, 817 (9th Cir.2001) (ellipsis in original) (quotation marks omitted); see also Daso v. The Grafton School, Inc., 181 F.Supp.2d 485, 493 (D.Md.2002) (“The word ‘nigger’ is more than [a]’mere offensive utterance’ .... No word in the English language is as odious or loaded with as terrible a history.”); NLRB v. Foundry Div. of Alcon Indus., Inc., 260 F.3d 631, 635 n. 5 (6th Cir.2001) (“That the word ‘nigger’ is a slur is not debatable.”). “Perhaps no single act can more quickly alter the conditions of employment and create an abusive working environment than the use of an unambiguously racial epithet such as ‘nigger’ by a supervisor in the presence of his subordinates.” Rodgers v. Western-Southern Life Ins. Co., 12 F.3d 668, 675 (7th Cir.1993) (citations and internal quotation marks omitted). The direct verbal attack on McGinest and the prevalence of graffiti containing a racial slur evocative of lynchings and racial hierarchy are significant exacerbating factors in evaluating the severity of the racial hostility.9
The district court observed that there was little evidence of racial animus for a number of the incidents described by McGinest, noting with approval GTE’s contention that “there is no necessary association between African Americans and drug dealers.” However, the Third Circuit has explained persuasively that “the use of *1117‘code words’ can, under circumstances such' as we encounter here, violate Title VII.” Aman v. Cort Furniture Rental Corp., 85 F.3d 1074, 1083 (3d Cir.1996). The Third Circuit went on to note:
[A] reasonable jury could conclude that the intent to discriminate is implicit in these comments. There are no talis-manic expressions which must be invoked as a condition-precedent to the application of laws designed to protect against discrimination. The words themselves are only relevant for what they reveal — the intent of the speaker. A reasonable jury could find that state-' ments like the ones allegedly made in this case send a clear message and carry the distinct tone of racial motivations and implications. They could be seen as conveying the message that members of a particular race are disfavored and that members of that race are, therefore, not full • and equal members of the workplace.
Id. (citations omitted)’.10 The reference to McGinest as a “drug dealer” might certainly be deemed to be a code word or phrase. In fact, reported cases have recognized the racial motivations behind this and other comments and slurs experienced by McGinest. See, e.g., Daniels v. Essex Group, Inc., 937 F.2d 1264, 1273 (7th Cir.1991) (noting that employer engaged in a “not-so-subtle attempt to link drugs ... with the plaintiff simply because he is black”); Swinton, 270 F.3d at 799 (noting that a “[rjeference to ‘Pontiac’ as an acronym for ‘Poor old nigger thinks it’s a Cadillae’ ” was a “racially offensive joke”); Jones v. City of Overland Park, 1994 WL 583153 (D.Kan.1994) (recognizing reference to plaintiff as “Aunt Jemima” as one factor in hostile environment). GTE’s attempt to deny the possible racial overtones of many of the comments made to McGi-nest or uttered in his presence indicates a willful blindness to racial stereotyping.
The district court discounted the insults and hostile actions directed at McGinest by both Noson and DeLeon, reasoning that because Ketchum, a white worker, was also targeted, this behavior did not constitute actionable racial harassment.' The district court erred in ignoring these interactions for several reasons. First, if racial hostility pervades a workplace, a plaintiff may establish a violation of Title VII, even if such hostility was not directly targeted at the plaintiff. See, e.g., Woods, 925 F.2d at 1202 (holding that work environment was racially hostile where “Woods was surrounded by racial hostility, and subjected directly to some of it”); Stingley, 796 F.Supp. at 426, 428 (finding racial and sexual harassment based in part on "use of racist nicknames and slurs about another worker in presence of plaintiff); Kishaba v. Hilton Hotels Corp., 737 F.Supp. 549, 554 (D.Haw.1990) (“Even if Plaintiff herself was never the object of racial harassment, she might nevertheless have a Title VII claim if she were forced to work in an atmosphere in which such harassment was pervasive.”). McGinest testified at his deposition that DeLeon directed racially charged com*1118ments at Ketchum specifically in order to anger McGinest. If racial animus motivates a harasser to make provocative comments in the presence of an individual in order to anger and harass him, such comments are highly relevant in evaluating the creation of a hostile work environment, regardless of the identity of the person to whom the comments were superficially directed.
Secondly, our case law is clear that the fact that an individual “consistently abused men and women alike” provides no defense to an accusation of sexual harassment. Steiner, 25 F.3d at 1463; see also id. at 1464. DeLeon’s use of racially charged words to goad both black and white employees makes his conduct more outrageous, not less so; as in Steiner, were the conduct sufficiently severe or pervasive it might indeed raise the possibility that Ketchum himself could raise a claim of discrimination. Id.
Thirdly, the district court overlooked testimony that Ketchum was harassed because of his association with black employees. “Title VII has ... been held to protect against adverse employment actions taken because of the employee’s close association with black friends or coworkers....” ARTHUR LARSON, EMPLOYMENT DISCRIMINATION, § 51.02 (2d ed.2003); cf. Taylor v. Western & Southern Life Ins. Co., 966 F.2d 1188 (7th Cir.1992) (affirming Title VII judgment for employee subjected to discrimination because of interracial marriage); Brosmore v. City of Covington, 1993 WL 762881 (E.D.Ky.1993) (noting significance under Title VII of detriment due to interracial association). Ketchum was not harassed for being white, nor were racial slurs mocking or insulting whiteness directed at him. Instead, the evidence suggests that he was harassed for making friendships that crossed racial lines, and for his acts of solidarity.11 Hostile conduct that attempts to sever or punish only those friendships that are interracial might certainly “pollute[ ] the victim’s workplace,” Steiner, 25 F.3d at 1463, and the district court erred in failing to consider this fact.
For purposes of summary judgment, McGinest persuasively demonstrates that he was subjected to a hostile work environment. He has presented evidence that over the past ten to fifteen years several racial incidents occurred each year, ranging in severity from being called racially derogatory names to experiencing a potentially life-threatening accident. As even the dissent recognizes, McGinest has raised a genuine issue of material fact with regard to the existence of a racially hostile workplace.
B. Analysis of Remedial Measures
Because we conclude, for purposes of summary judgment, that McGinest suffered a hostile work environment, we must consider whether GTE is liable for the harassment. As a preliminary matter, we address the district court’s overall approach to the question of remediation. The district court considered the sufficiency of GTE’s remedial measures on an event-by-event basis, stating: “After eliminating the incidents for which McGinest’s proof is wholly inadequate, and those incidents to which [GTE] has adequately responded, McGinest’s case rests on a few sporadic occurrences of arguably racially motivated conduct.” Although the district court’s approach does not appear unreasonable at first blush, it led the court to underestimate the impact of the environ*1119ment on McGinest and underemphasize GTE’s responsibility to take remedial action to discourage discriminatory conduct. Instead, a court must first assess whether a hostile work environment existed, and then determine whether the response was adequate as a whole.
An employer’s liability for harassing conduct is evaluated differently when the harasser is a supervisor as opposed to a coworker. Swinton, 270 F.3d at 803. An employer is vicariously liable for a hostile environment created by a supervisor, although such liability is subject to an affirmative defense. Nichols, 256 F.3d at 877 (citing Faragher v. City of Boca Raton, 524 U.S. at 780, 118 S.Ct. 2275, 141 L.Ed.2d 662). “If, however, the harasser is merely a coworker, the plaintiff must prove that ... the employer knew or should have known of the harassment but did not take adequate steps to address it.” Swinton, 270 F.3d at 803.
1. Vicarious Liability for Acts by Supervisors
An employer may raise a two-pronged affirmative defense to avoid vicarious liability for a hostile environment created by a supervisor.12 Nichols, 256 F.3d at 877. Although GTE mentions this defense in its motion for summary judgment, it does not raise it before us. In consequence, we assume that GTE is liable for the acts of its supervisors, and we leave it to the district court to evaluate the defense if it is raised on remand. See Smith v. Mash, 194 F.3d 1045, 1052 (9th Cir.1999). Thus, for the purposes of summary judgment we assume that GTE is liable for the offensive comments by coordinator Hughes13 and supervisor Ledbetter, supervisor Roberts’ denial of bonus pay for McGinest’s overtime while a relief supervisor and refusal to provide for McGinest’s automotive safety, and the derogatory comments and exposure to hazardous industrial situations by supervisor Noson.
2. Liability for Actions by Coworkers
“[E]mployers are liable for failing to remedy or prevent a hostile or offensive work environment of which management-level employees knew, or in the exercise of reasonable care should have known.” El*1120lison v. Brady, 924 F.2d at 881 (quoting EEOC v. Hacienda Hotel, 881 F.2d 1504, 1515-16 (9th Cir.1989)); Swinton, 270 F.3d at 803. GTE had actual knowledge of the events of which McGinest informed his immediate supervisor or manager, including the offensive comments by coworkers Daniel DeLeon, Jim Frick and Alex Tal-madge, as well as the one incident of graffiti that was reported. Additionally, GTE had imputed knowledge regarding the remaining incidents of racist graffiti, because managers also used the restrooms and other facilities where this graffiti was prevalent.
GTE may nonetheless avoid liability for such harassment by undertaking remedial measures “reasonably calculated to end the harassment.” Ellison, 924 F.2d at 882; see also Yamaguchi v. United States Dep’t of the Air Force, 109 F.3d 1475, 1482 (9th Cir.1997). “The reasonableness of the remedy depends on its ability to: (1) ‘stop harassment by the person who engaged in the harassment;’ and (2) ‘persuade potential harassers to refrain from unlawful conduct.’ ” Nichols, 256 F.3d at 875 (quoting Ellison, 924 F.2d at 882). To be adequate, an employer must intervene promptly. Intlekofer v. Turnage, 973 F.2d 773, 778 (9th Cir.1992). Remedial measures must include some form of disciplinary action, Yamaguchi, 109 F.3d at 1482, which must be “proportionate[] to the seriousness of the offense,” Ellison, 924 F.2d at 882 (“Title VII requires more than a mere request to refrain from discriminatory conduct.”).
GTE took action by counseling DeLeon and by painting over the racial graffiti reported in April 1998. GTE alleges that these remedial measures stopped the harassment, and were therefore sufficient to protect it from liability. However, it is clear that McGinest has presented sufficient evidence to establish disputed issues of material fact with regard to the adequacy of the remedial measures taken by GTE. In fact, on the record before us, GTE would be unable to avoid liability through its remedial measures.
First, GTE only responded to the one act of graffiti that was reported, despite the fact that GTE knew or should have known of numerous other instances. Inaction constitutes a ratification of past harassment, even if such harassment independently ceases. Fuller v. City of Oakland, 47 F.3d 1522, 1529 (9th Cir.1995) (noting that Title VII condemns “the existence of past harassment, every bit as much as the risk of future harassment”); Nichols, 256 F.3d at 875-76 (“When the employer undertakes no remedy, or where the remedy does not end the current harassment and deter future harassment, liability attaches for both the past harassment and any future harassment.”).
Additionally, although painting over the graffiti was a necessary first step, the record before us reveals no actions taken by GTE to ensure that this recurrent problem would cease,14 and in fact it did *1121not cease. Thus, this case resembles Daniels v. Essex Group, in which inadequate remediation was found where similar racist graffiti reappeared after being painted over, “the defendant made virtually no effort to investigate the incidents,” 937 F.2d at 1275, and management neither called a meeting of the workforce to condemn the racial harassment nor issued “a warning announcing the employer’s abhorrence of racial harassment,” id. at 1267.
Furthermore, the reactions of management upon learning about the graffiti indicate that the incident was not taken seriously. After being informed about the graffiti, supervisor Roberts first joked that he himself was responsible for it, and then added an additional “humorous” comment that had racial overtones.15 Rather than remedying the harassment, Roberts’ behavior appears to have added to it.
GTE’s remediation of DeLeon’s racial comments also gives cause for concern. Although counseling and a warning may suffice if successful in stopping the harassment, see Intlekofer, 973 F.2d at 779, GTE did not issue this warning until McGinest had filed a complaint with the EEOC. In fact, McGinest had informed his manager or immediate supervisor of the events involving Noson, Hughes, DeLeon, and others, to no avail. In each of these cases, GTE did not respond until McGinest initiated formal proceedings. This delay does not satisfy Title VII’s requirement of prompt remedial action. See, e.g., Fuller, 47 F.3d at 1528; Intlekofer, 973 F.2d at 778; Steiner, 25 F.3d at 1464.
Taken as a whole, GTE’s responses were troubling for another reason. We have been clear that in order to be adequate, remedial actions must be designed not only to prevent future conduct by the harasser, but also by other potential harasses. See, e.g., Fuller, 47 F.3d at 1528; Nichols, 256 F.3d at 875; Ellison, 924 F.2d at 882. GTE’s actions may have been successful in persuading identified harassers to cease their activities. But over a ten-year period, McGinest was subjected to inappropriate comments by a minimum of six individuals, and was allegedly physically endangered or financially harmed through the actions of several others. On the record before us, GTE took no action to ensure that this level of harassment did not continue for the rest of MeGinest’s tenure at the company.
IV.
FAILURE TO PROMOTE
The remaining two claims raised by McGinest involve GTE’s failure to promote him to the position of Outside Plant Construction Installer Supervisor in October 1998. McGinest alleges that he was denied this promotion because of racial discrimination and in retaliation for his complaint to the EEOC regarding the hostile work environment.
A. Racial Discrimination
Under Title VII, an individual suffers disparate treatment “when he or she is ‘singled out and treated less favorably than others similarly situated on account of race.’ ” Jauregui v. City of Glendale, 852 F.2d 1128, 1134 (9th Cir.1988) (quoting Gay v. Waiters’ & Dairy Lunchmen’s Union, 694 F.2d 531, 537 (9th Cir.1982)); 42 *1122U.S.C. § 2000e-2(a) (2003). Failure to promote is a common manifestation of disparate treatment. See Texas Dep’t of Community Affairs v. Burdine, 450 U.S. 248, 253, 101 S.Ct. 1089, 67 L.Ed.2d 207 (1981); Warren v. City of Carlsbad, 58 F.3d 439, 440-41 (9th Cir.1995); Jauregui, 852 F.2d at 1134.
“[T]he plaintiff in a disparate treatment case must show the employer’s intent to discriminate, but intent may be inferred from circumstantial evidence.” Id. (quoting Domingo v. New England Fish Co., 727 F.2d 1429, 1435 (9th Cir.1984)). The parties debate at length the question of whether McGinest adduced direct or circumstantial evidence of discrimination, and the relevance of the resolution of this question to the proper analytical framework by which a disparate treatment claim is evaluated. Their confusion is understandable considering the proliferation of conflicting case law on this question. See Costa v. Desert Palace, 299 F.3d 838, 852-53 (9th Cir.2002) (reviewing case law and describing it as a “quagmire that defies characterization,” “chaos,” and a “morass”), aff'd by 539 U.S. 90, 123 S.Ct. 2148, 156 L.Ed.2d 84 (2003). However, the Supreme Court recently brought much-needed clarity to this area of law when it affirmed our en banc opinion in Costa v. Desert Palace.
In Costa, the Supreme Court held that circumstantial and direct evidence should be treated alike, noting: “Circumstantial evidence is not only sufficient, but may also be more certain, satisfying and persuasive than direct evidence.” 123 S.Ct. at 2154 (quoting Rogers v. Missouri Pacific R.R. Co., 352 U.S. 500, 508 n. 17, 77 S.Ct. 443, 1 L.Ed.2d 493 (1957)). Because the Supreme Court held that the distinction between direct and circumstantial evidence is irrelevant to determining what analytical framework to apply, we need not resolve the parties’ arguments regarding the proper characterization of McGinest’s evidence.
Our decision in Costa establishes that although the McDonnell Douglas burden shifting framework16 is a useful “tool to assist plaintiffs at the summary judgment stage so that they may reach trial,” “nothing compels the parties to invoke the McDonnell Douglas presumption.” 299 F.3d at 855. Rather, when responding to a summary judgment motion, the plaintiff is presented with a choice regarding how to establish his or her case. McGinest may proceed by using the McDonnell Douglas framework, or alternatively, may simply produce direct or circumstantial evidence demonstrating that a discriminatory reason more likely than not motivated GTE. Id. (noting that plaintiff may succeed by introducing “other sufficient evidence-direct or circumstantial-of discriminatory intent”).
The district court applied the McDonnell Douglas test. It determined that McGinest established a prima facie case of failure to promote due to racial discrimination. McGinest 1) is a member of a protected class; 2) applied for and was qualified for an open job; 3) was rejected for that job; and 4) rather than filling the position by promoting any of the interviewees, GTE transferred a white manager into the position.17 GTE produced a legiti*1123mate, nondiscriminatory reason for the action, claiming that it was due to a hiring freeze. The district court concluded, however, that McGinest failed to produce evidence indicating that the reason given by GTE was a pretext, and thus granted summary judgment to GTE.
Once the defendant produces evidence of a legitimate nondiscriminatory reason to counter the plaintiffs demonstration of a prima facie case, the McDonnell Douglas' “presumption of discrimination ‘drops out of the picture.’ ” Reeves v. Sanderson Plumbing Prod., Inc., 530 U.S. 133, 143, 120 S.Ct. 2097, 147 L.Ed.2d 105 (2000) (quoting St. Mary’s Honor Center v. Hicks, 509 U.S. 502, 511, 113 S.Ct. 2742, 125 L.Ed.2d 407 (1993)). Because the district court correctly found that the first' two steps of the McDonnell Douglas framework had been established, “the sole remaining issue was ‘discrimination vel non.’ ” Id. (quoting U.S. Postal Serv. Bd. of Governors v. Aikens, 460 U.S. 711, 714, 103 S.Ct. 1478, 75 L.Ed.2d 403 (1983)). Thus, despite the parties’ vociferous contentions, in this case it is not particularly significant whether McGinest relies on the McDonnell Douglas presumption or, whether he relies on direct or circumstantial evidence of discriminatory intent to meet his burden. Under either approach, McGinest must produce some evidence suggesting that GTE’s failure to promote him was due in part or whole to discriminatory intent, and so must counter GTE’s explanation that a hiring freeze accounted for its failure to promote him.
As McGinest, argues, the absence of any documentation confirming that a company hiring freeze was in place during the relevant time period is sufficient to raise a genuine factual dispute as to whether the asserted reason was pretextual. ‘Indeed, even if such decisions were commonly conveyed to yard managers by word-of-mouth, the fact that a company the size of GTE does not have a memorandum, meeting notes, or other evidence of this hiring freeze or the financial difficulties. that allegedly spurred the hiring freeze provides circumstantial evidence that- the hiring freeze did .not in fact exist.18
“Proof that the defendant’s explanation is unworthy of credence is [a] form of circumstantial evidence that is probative of intentional discrimination, and it may be quite persuasive.” Reeves, 530 U.S. at 147, 120 S.Ct. 2097. Additionally, GTE’s permissive response to harassing actions undertaken by coworkers and supervisors, combined with the absence of black supervisors and managers in the workplace, also is circumstantial evidence of pretext. See McDonnell Douglas, 411 U.S. at 804-05, 93 S.Ct. 1817 (noting that possible, methods of demonstrating pretext include “treatment of [the employee] during his prior term of employment ... and [the employer’s] general policy and practice with respect to minority employment,” such as *1124information demonstrating “a general pattern of discrimination against blacks”); Warren, 58 F.3d at 443-44 (holding that plaintiff raised a genuine issue of material fact as to employer’s motive by showing that less-qualified white employees were promoted over him, combined with racist remarks and statistical evidence); Bergene v. Salt River Project Agric. Improvement & Power Dist., 272 F.3d 1136, 1143 (9th Cir.2001) (holding that absence of female supervisors was one factor establishing pretext for failure to promote).
We have held that “very Iittle[ ] evidence is necessary to raise a genuine issue of fact regarding an employer’s motive; any indication of discriminatory motive ... may suffice to raise a question that can only be resolved by a fact-finder.” Schnidrig, 80 F.3d at 1409. “When [the] evidence, direct or circumstantial, consists of more than the McDonnell Douglas presumption, a factual question will almost always exist with respect to any claim of a nondiscriminatory reason.” Sischo-Nownejad, 934 F.2d at 1111; see also Lam, 40 F.3d at 1564. As the district court recognized, this is a close case. Such uncertainty at the summary judgment stage must be resolved in favor of the plaintiff. Id. (“We require very little evidence to survive summary judgment precisely because the ultimate question is one that can only be resolved through a ‘searching inquiry’one that is most appropriately conducted by the fact finder, upon a full record.”). Because a number of factors cast doubt upon GTE’s proffered explanation for its failure to promote McGinest, while providing support for his contention regarding racial discrimination, McGinest has met his burden of showing “a genuine factual issue with regard to discriminatory intent.” Lam, 40 F.3d at 1559.
B. Retaliation
Section 704 of Title VII prohibits retaliation against an employee for opposing unlawful discrimination. 42 U.S.C. § 2000e-3(a) (2003). Like discrimination, retaliation may be shown using the McDonnell Douglas burden shifting framework. To establish a prima facie case of retaliation under Title VII, McGi-nest must show 1) that he acted to protect his Title VII rights; 2) that an adverse employment action was thereafter taken against him; and 3) that a causal link existed between the two events. Steiner, 25 F.3d at 1464. If a prima facie case is established, the burden then shifts to the employer to proffer an alternative explanation for its action, which the employee may attempt to rebut.
McGinest has established the first and second' prongs of the prima facie case.19 However, McGinest has not presented sufficient evidence to demonstrate a causal link between his complaint and the denial of the promotion. Because the two events were separated by a year and a half, the timing alone does not establish a connection, and McGinest does not offer any other explanation. See Villiarimo v. *1125Aloha Island Air, Inc., 281 F.3d 1054, 1065 (9th Cir.2002). Thus, we affirm the district court’s dismissal of the retaliation claim.
CONCLUSION
We reverse the district court’s grant of summary judgment on the first two counts, and remand to the district court for further proceedings. McGinest established the existence of material questions of fact with regard to whether GTE created and failed to remedy a racially hostile working environment. McGinest also has shown a genuine issue of material fact as to whether GTE’s failure to promote him was based on racial discrimination. However, we affirm the district court’s dismissal of the retaliation claim.
Appellant shall recover costs on appeal.
AFFIRMED in part, REVERSED in part, and REMANDED.
. Although GTE is now owned by Verizon, we continue to refer to it by the name under which it was sued.
. The memorandum read in full:
On June 15, 1999, an investigation was held with you regarding a racial statement you supposedly made to another employee.
Upon the conclusion of this investigation, which showed your failure to adhere to Company policy, I have no alternative but to issue this disciplinary memorandum.
You will be reviewed on the Company’s policy regarding GTE's Equal Employment Opportunity, Affirmative Action and Workforce Diversity. Any further violations of this nature could result in your termination from GTE Network Services.
This disciplinary memorandum will be removed if you have no further violations for a period of one year.
I am confident that you will succeed in your efforts. If I can be of any assistance, please feel free to see me.
. GTE notes that DeLeon is originally from Cuba, and hence may have been unaware that this phrase is a racial insult, although he has been in the United States for over 20 years. DeLeon’s explanation is somewhat less believable in light of his uncontested use of the clearly racial phrase “mammy.” Moreover, McGinest testified that DeLeon was "a very intelligent person, and he ... understood exactly what he was saying, and he was being racist.”
. Leigh Washington, the African-American coworker who reported seeing this phrase, stated that he complained for weeks before GTE painted it over.
. GTE contests McGinest's version of the facts. However, it is axiomatic that disputes about material facts and credibility determinations must be resolved at trial, not on summary judgment. See, e.g., Lam, 40 F.3d at 1559. Indeed, the Supreme Court has instructed that at the summary judgment stage, ''[t]he evidence of the non-movant is to be believed, and all justifiable inferences are to be drawn in his favor.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). The district court, contrary to these fundamental principles, accepted GTE's allegations that many of the events attested to by McGinest either did not occur as McGinest described or were not racially motivated. For example, although McGinest and others testified that the garage foreperson treated black employees worse than white employees, the district court emphasized one deponent's acknowledgment that the foreperson's animus against the black employees may have been due simply to personality. Similarly, the district court concluded that "there is no credible evidence of a differential application of any 'unwritten rule' regarding relief supervisor overtime.” However, in both of these instances McGinest provided detailed deposition testimony describing his personal observations regarding the manner in which African-American employees were disfavored in relation to white employees. This testimony did not consist of mere "conclusory allegations,” which would be insufficient to defeat a motion for summary judgment. Nat’l Steel Corp. v. Golden Eagle Ins. Co., 121 F.3d 496, 502 (9th Cir.1997). Rather, McGinest's testimony would suffice to enable a reasonable trier of fact to conclude that discrimination had occurred, without the need for further corroborating evidence. See United States v. One Parcel of Real Prop., 904 F.2d 487, 491-92 (9th Cir.1990). At trial, the trier of fact might deem such testimony to lack credibility, and disregard it. However, when ruling on a summary judgment motion, the district court is not empowered to malte credibility determinations or weigh conflicting evidence. Liberty Lobby, Inc., 477 U.S. at 255, 106 S.Ct. 2505; see also SEC v. Koracorp Indus., Inc., 575 F.2d 692, 699 (9th Cir.1978).
. Whether the allegations regarding Noson are admissible at trial for pwposes of liability is a close question. The principal case on this issue is National Railroad Passenger Corp. v. Morgan, 536 U.S. 101, 122 S.Ct. 2061, 153 L.Ed.2d 106 (2002); a case the district court did not have the benefit of when it issued its summary judgment ruling.
In Morgan, the Court held that "consideration of the entire scope of a hostile work environment claim, including behavior alleged outside the statutory time period, is permissible for purposes of assessing liability, so long as an act contributing to that hostile environment takes place within the statutory time period.” 536 U.S. 101, 105, 122 S.Ct. 2061, 153 L.Ed.2d 106. As the dissent points out, Morgan itself does not offer precise guidance on how to evaluate whether an act that falls outside the statutory time period can nonetheless be considered for liability purposes. Dissent Op. at 1127, n. 2. Morgan implies that a previous incident would not be part of the same hostile work environment claim, and therefore time-barred, if it "had no relation to” the later acts, or there was intervening action taken by the employer. 536 U.S. at 118, 122 S.Ct. 2061. Additionally, allegations that would ordinarily be time-barred, but are nonetheless part of a single hostile work environment claim, are still subject to the equitable defenses of waiver, estoppel, and equitable tolling. Id. at 121, 122 S.Ct. 2061.
Here, viewing the evidence in the light most favorable to McGinest, it is possible that the events concerning Noson in the early 1990s are “part of one unlawful employment practice” giving rise to a "single claim.” Id. at 118, 122 S.Ct. 2061. Noson's harassment spanned several years ending in the early 1990s, involving, among other things, a thinly-veiled racially derogatory comment. While the dissent places reliance on the fact that GTE did ask Noson to apologize to McGinest, GTE’s unsatisfactory response is evidenced by the fact that it considered Noson's comments and behavior to be merely “shoptalk” — undermining any claim that GTE viewed this as a serious problem.
However, as noted before, neither the district court nor the parties had the benefit of the Supreme Court’s decision in Morgan. As a result, the record is under-developed in this regard. Therefore, upon remand the district court may decide in the first instance whether, under Morgan, the allegations regarding Noson are sufficiently related such that they can be considered for purposes of liability and, if so, whether they should nonetheless be equitably barred. We note that even if the Noson allegations cannot be considered for purposes of liability, they nonetheless may still be admissible at trial for other limited purposes. As Morgan notes in the context of discrete discriminatory acts, the statute does not “bar an employee from using the prior [untimely] acts as background evidence in support of a timely claim.” 536 U.S. at 113, 122 S.Ct. 2061; see also Lyons v. England, 307 F.3d 1092, 1108 (9th Cir.2002) (holding that under Morgan "appellants are permitted to offer evidence of the pre-limitations discriminatory detail assignment scheme in the prosecution of their timely claims”). The dissent itself reaches the conclusion that McGi-nest's hostile work environment claim survives summary judgment and thus, even on the dissent's own terms, it would be premature to limit the type of evidence McGinest can present at trial in support of his hostile work environment claim. Indeed, the dissent appears to suggest that the Noson allegations could not even be considered as background evidence to McGinest's hostile work environment claim. See Dissent Op. at 1127-28. Not only would this position run contrary to our precedent in Lyons, but it also would supplant the district court’s role under Federal Rule of Civil Procedure 16 to fashion a pretrial order that would govern the course of the trial by preemptively purporting to exclude potentially admissible evidence.
. In determining whether the deprivation of the overtime received by relief supervisors was discriminatory, it is not relevant that the practice of awarding such overtime was disfavored or ultimately discontinued by the com*1115pany. What is critical, however, is whether McGinest was treated differently because of his race. GTE contends that McGinest was paid nine and a half hours of overtime over a six month period during the time that the violations allegedly took place. This response only shows that the facts are in dispute regarding the extent of the alleged practice.
. Following the Supreme Court’s decision in Harris v. Forklift Systems, which referred to "an environment that a reasonable person would find hostile or abusive,” 510 U.S. at 21, 114 S.Ct. 367, a number of courts refused to apply a reasonable person standard based on the perspective of a person sharing the characteristics of the plaintiff. See, e.g., Gillming v. Simmons Indus., 91 F.3d 1168, 1172 (8th Cir.1996); Watkins v. Bowden, 105 F.3d 1344, 1355-56 (11th Cir.1997). However, in On-cale, the Supreme Court recharacterized the Harris statement, making it clear that it is proper to use an individualized standard based upon the characteristics of the plaintiff. 523 U.S. at 78, 118 S.Ct. 998 ("We have emphasized, moreover, that the objective severity of harassment should be judged from the perspective of a reasonable person in the plaintiff's position, considering ‘all the circumstances.’ ”).
. Moreover, a trier of fact might certainly conclude that, in light of Hughes’ use of a racial slur, his other abusive remarks to McGinest were also motivated by racial hostility.
. The Third Circuit explained the significance of these holdings as follows:
Anti-discrimination laws and lawsuits have 'educated’ would-be violators such that extreme manifestations of discrimination are thankfully rare. Though they still happen, the instances in which employers and employees openly use derogatory epithets to refer to fellow employees appear to be declining. Regrettably, however, this in no way suggests that discrimination based upon an individual’s race, gender, or age is near an end. Discrimination continues to pollute the social and economic mainstream of American life, and is often simply masked in more subtle forms.
85 F.3d at 1081-82.
. For example, following Noson's statement to McGinest that "only drug dealers can afford nice gold chains,” Ketchum bought himself a gold chain which he subsequently wore to work every day.
. The employer must show that 1) it exercised reasonable care to prevent and correct promptly any invidious harassment, and 2) that the plaintiff unreasonably failed to take advantage of any preventative or corrective opportunities provided by the employer or avoid harm otherwise. Nichols, 256 F.3d at 877.
. GTE challenges McGinest’s description of Hughes as his supervisor, but does not assert that Hughes was not a supervisor. Our case law does indeed distinguish between a situation in which a harasser supervises the plaintiff, where vicarious liability is available, versus those situations in which a harasser is a supervisor and yet does not supervise the plaintiff. See Swinton, 270 F.3d at 805. An employer is vicariously liable for actions by a supervisor who has "immediate (or successively higher) authority over the employee.” Faragher, 524 U.S. at 806, 118 S.Ct. 2275. Thus, this distinction is not dependent upon job titles or formal structures within the workplace, but rather upon whether a supervisor has the authority to demand obedience from an employee. Cf. Burrell v. Star Nursery, Inc., 170 F.3d 951, 956 (9th Cir.1999).
The affidavits and deposition transcripts establish that the supervisorial structure of GTE was quite complex. See, e.g., Declaration of McGinest (explaining "I work with five or six supervisors at one time”). If Hughes engaged in supervision of or had authority over McGi-nest, he would qualify as McGinest's supervisor even if the company did not define his role this way. Swinton, 270 F.3d at 803-05. The question of who was considered a supervisor by GTE, and whether its job categories suffice to satisfy the demarcations drawn under the case law interpreting Title VII is properly resolved by the district court on a more extensive factual record.
. GTE took no action to send a message that such graffiti was intolerable, or to recognize that it differed in kind from other graffiti prevalent in the bathrooms. Snell v. Suffolk County, 782 F.2d 1094, 1104-05 (2d Cir.1986). GTE could have heavily emphasized to all employees that serious punishment would result if the perpetrators of this or future incidents were caught, underlining the fact that such behavior was neither tolerated or condoned. Nichols, 256 F.3d at 876; Daniels, 937 F.2d at 1275. At a minimum, GTE could have informed the offended employees that it would make efforts to prevent the reappearance of such graffiti, and had a manager check the areas in question on a regular basis to ensure that this problem did not recur. Nichols, 256 F.3d at 876 (noting that employer conducted spot checks). On the *1121record before us, GTE did none of these things.
. Since Roberts responded to news of the objectionable graffiti by quoting Rodney King's question, “Why can’t we all just get along?” which was itself an allusion to black-white racial strife, the evidence before us implies that Roberts may well have understood the nature of the graffiti.
. Under the McDonnell Douglas burden shifting framework, a plaintiff must first establish a prima facie case of unlawful discrimination. The burden then shifts to the employer to articulate a legitimate, nondiscriminatory reason for the action. If the employer does so, the plaintiff must show that the articulated reason is pretextual. McDonnell Douglas Corp., 411 U.S. at 802-804, 93 S.Ct 1817.
. Although this fourth factor is not identical to the one employed in McDonnell Douglas, it is widely recognized that the test is a flexible *1123one and the prima facie case described was "not necessarily applicable in every respect to differing factual situations.” McDonnell Douglas, 411 U.S. at 802 n. 13, 93 S.Ct. 1817; see also Swierkiewicz v. Sorema, 534 U.S. 506, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002). GTE's suggestion that McGinest does not establish the fourth factor is unpersuasive.
. McGinest requests that we take judicial notice of GTE’s Annual Report from 1998 as well as a news release from the California Public Utilities Commission. These documents allegedly show that, contrary to the explanation given for the hiring freeze, GTE was in glowing financial health in 1998. However, since- these documents were not presented to the district court, we do not consider this information in reaching our conclusion.
. By filing a complaint with the EEOC, McGinest engaged in the quintessential action protected by § 704. See Ray v. Henderson, 217 F.3d 1234, 1240 n. 3 (9th Cir.2000) (“As the statutory language ... indicates, filing a complaint with the EEOC is a protected activity.”); Hashimoto v. Dalton, 118 F.3d 671, 680 (9th Cir.1997) (holding that simply meeting with EEO counselor is protected activity because it constitutes participation “in the machinery set up by Title VII to enforce its provisions”). An adverse employment action is one that "is reasonably likely to deter employees from engaging in protected activity,” Ray, 217 F.3d at 1243; clearly, denial of a promotion qualifies as an adverse employment action. See, e.g., Bergene, 272 F.3d at 1141; Brooks v. City of San Mateo, 229 F.3d 917, 928 (9th Cir.2000).