The California Court of Appeal recently held in Brennan v. Townsend & O’Leary Enterprises, Inc. that a trial court properly granted a judgment not withstanding the verdict (JNOV) for insufficient evidence in a sexual harassment case. The case involved a female plaintiff who alleged that she received an e-mail that was harassing because of gender, and also alleged four incidents of sexual harassment that occurred over a four-year period and were perpetrated by three different people.