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604, 613 (1987) ("[section] 1981, at a minimum, reaches discrimination against an individual 'because he or she is genetically part of an ethnically and physiognomically distinctive sub-grouping of homo sapiens.
However, for the purposes of the present study, we will use the term ethnicity to refer to individuals' socially defined membership in putatively cultural, but sometimes also physiognomically, linguistically, geographically, or ancestrally based, ethnic groups.