Last week, Acting Assistant Secretary for Civil Rights Craig Trainor issued a Dear Colleague Letter (DCL) announcing that effective immediately, the U.S. Department of Education’s Office for Civil Rights (OCR) will revert to the provisions of the 2020 Title IX Rule and. Trainor cited the U.S. District Court for the Eastern District of Kentucky decision that vacates the 2024 Title IX Rule which provided for “gender identity,” a category that runs counter to President Trump’s Defending Women executive order that acknowledges only two genders —birth assignment as male or female. Because the reversion to the 2020 Title IX Rule subverts requirements under the Administrative Procedures Act, a federal law requiring agencies to follow a “notice-and-comment” rulemaking process when developing or revising regulations, and states like California have said “all means all” -and they will follow state law, not the Trump Administration’s DCL- the process to implement Title IX consistently across the nation is unclear.