Case 1:18-cv-01011-RMC Document 42 Filed 08/09/19 Page 11 of 19 intentionally or recklessly (3) causes the plaintiff severe emotional distress.’” Paul v. Howard Univ., 754 A.2d 297, 307 (D.C. 2000) (quoting Howard Univ. v. Best, 484 A.2d 958, 985 (D.C. 1984)). The conduct must be “so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized society.” Purcell v. Thomas, 928 A.2d 699, 711 (D.C. 2007). In deciding whether alleged conduct is “extreme and outrageous,” the court must consider: “(1) applicable contemporary community standards of offensiveness and decency, and (2) the specific context in which the conduct took place.” The “liability clearly does not extend to mere insults, indignities, threats, annoyances, petty oppressions, or other trivialities,” although statements that were considered a “petty oppression,” “trivial” or merely “inconsiderate and unkind” fifty years ago may be “extreme and outrageous” conduct under “today’s social standards and principles (or viceversa).” Courts have applied a balancing test to determine whether the alleged conduct “violates prevailing social norms and is sufficiently outrageous to ensure that the advantage to society of preventing such harm seems greater than the advantage of leaving ill-disposed persons free to seek their happiness in inflicting it.” Burnett v. Am. Fed’n of Gov’t Emps., 102 F. Supp. 3d 183, 190 (D.D.C. 2015) (quoting King v. Kidd, 640 A.2d 656, 668-69 (D.C. 1993)). “Creation of a hostile . . . environment by racial or sexual harassment may, upon sufficient evidence, constitute a prima facie case of intentional infliction of emotional distress.” Best, 484 A.2d at 986. “‘Repeated harassment . . . may compound the outrageousness of incidents which, taken individually, might not be sufficiently extreme to warrant liability.’” Id. (quoting Boyle v. Wenk, 392 N.E.2d 1053, 1056 (Mass. 1979)). a. Mr. Anglin/Moonbase Holdings (Count IV) Ms. Dumpson alleges that Mr. Anglin’s article which mocked the noose incident and encouraged people to troll storm her was intended to inflict emotional distress. Am. Compl. ¶¶ 181-82. The encouraged harassment and online attacks ridiculed her because of her race and 11