In the short term, Ledbetter will spawn only confusion. First, courts will likely become more open to traditional equitable tolling of charge filing deadlines, which already serves as a discovery rule of sorts. This is especially so given footnote 10. Second, courts will likely continue to chip away at the exhaustion doctrine; the presumed difficulty of discovering the discriminatory motive will be the justification for these rulings. Interestingly, at the same time as the courts extend the time for filing because charging parties allegedly need additional time, they will still apply the pleading rules that presume that the only way to investigate a claim is through discovery. The one question that I cannot answer is whether Ledbetter is an indication of things to come or is merely a reflection of a changing environment for employers. It will be an interesting few years.