Price v. City of N.Y. 15 Civ. 5871 (KPF) (S.D.N.Y. Jun. 25, 2018) the violation of her First Amendment rights; she contends that Brooks's and Obe's departure from official policy caused the harm. 18 At the same time, the Court addresses the official-capacity claims against Brooks, Obe, and Pierre-Louis. -------44 43 Instead, Plaintiff appears to invoke three other theories of municipal liability under § 1983: (i) the existence of an unlawful practice by subordinate officials, which was so widespread and well settled as to constitute a custom or usage of the municipality, caused the constitutional violation; (ii) the failure to train amounted to deliberate indifference to the rights of those with whom the *43 municipality's employees interact, thereby causing the constitutional injury; and (iii) that the official responsible for establishing the policy, with respect to the subject matter in question to the specific action, caused the constitutional violation. (FAC ¶¶ 139-49). Plaintiff also asserts a Monell claim against the City based upon its alleged failure to train its employees about the interplay between social media use and the First Amendment. The Supreme Court has explained that "[a] municipality's culpability for a deprivation of rights is at its most tenuous where a claim turns on a failure to train." Connick, 563 U.S. at 61. "Where municipal liability is based on ... inaction, rigorous standards of culpability and causation must be applied to ensure against vicarious liability." Matusick v. Erie Cty. Water Auth., 757 F.3d 31, 73 (2d Cir. 2014) (internal quotation marks omitted) (quoting Bd. of Cty. Comm'rs of Bryan Cty., 520 U.S. at 405). Concerning the first theory, "Monell's policy or custom requirement is satisfied where a local government is faced with a pattern of misconduct and does nothing, compelling the conclusion that the local government has acquiesced in or tacitly authorized its subordinates' unlawful actions." Reynolds v. Giuliani, 506 F.3d 183, 192 (2d Cir. 2007). Plaintiff does not allege that any person besides herself was blocked by the City's social media moderators. She instead alleges that an informal but widespread custom must have existed because she was blocked on three occasions by three separate City employees. (FAC ¶ 139). But Plaintiff's allegations of three similar constitutional violations do not allow the Court plausibly to infer the existence of a widespread custom or practice that can be attributed to the City. See Jones, 691 F.3d at 85 (holding that three incidents "fell far short of showing a policy, custom, or usage of officers"); Giaccio v. City of New York, 308 F. App'x 470, 472 (2d Cir. 2009) (summary order) (stating that four similar constitutional violations "falls far short of establishing a practice that is 'so persistent or widespread' as to justify the imposition of municipal liability"); White v. City of New York, No. 15 Civ. 6696 (GHW), 2016 WL 4750180, at *12 (S.D.N.Y. Sept. 12, 2016) (holding that six incidents over five years were insufficient to plausibly allege the existence of *44 a municipal policy); Davis v. City of New York, 228 F. Supp. 2d 327, 346 (S.D.N.Y. 2002) ("[T]wo incidents of unconstitutional conduct by low-level employees in a city agency with over 35,000 employees can never provide a reasonable basis for finding a widespread or well-settled custom."). The Court therefore concludes that Plaintiff fails to allege plausibly that a widespread municipal custom exists. 45 In order for municipal liability to attach on a failure-to-train theory, "a municipality's failure to train its employees in a relevant respect must amount to 'deliberate indifference to the rights of persons with whom the [untrained employees] come into contact.'" Connick, 563 U.S. at 61 (citing City of Canton, 489 U.S. at 388). "A pattern of similar constitutional violations by untrained employees is ordinarily necessary to demonstrate deliberate indifference for purposes of failure to train." Id. at 62 (internal quotation marks and citation omitted). To allege deliberate indifference in the context of a failure-to-train *45 21