This case summary discusses a hypothetical Title IX case against Park City University for failing to add a women's golf team. The summary argues that unlike Brown University in Cohen v. Brown, Park City University cannot establish a history of expanding women's athletic opportunities, as it only added 7 women's teams between 1970-1990 and did not add any more teams until 2003. As such, Park City University failed to continue expanding its program in response to women's interests and abilities as required by Title IX.