This Law Firm Publication by Ogletree, Deakins, Nash, Smoak & Stewart, P.C., discusses the US District Court for the Southern District of New York's recent decision in Wang v. Phoenix Satellite Television US, Inc. dismissing an unpaid intern's hostile work environment, quid pro quo sexual harassment and retaliation suit under the New York State Human Rights Law (NYSHRL) and the New York City Human Rights Law (NYCHRL). The court held that because the intern was unpaid, she was not an employee under the NYSHRL and the NYCHRL and therefore was not covered by either law. Whether an unpaid intern qualifies as an employee under the NYCHRL had been a matter of first impression in New York state and federal courts.