What is the initial burden of establishing a case of disparate treatment under Title VII?

In a sex discrimination action under Title VII, the plaintiff bears the initial burden of establishing a prima facie case of disparate treatment by introducing evidence that gives rise to an inference of unlawful discrimination based on sex. 42 U.S.C. 2000e-2(a)(1); Sischo-Nownejad v. Merced Community College Dist., 934 F.2d 1104, 1109 (9th Cir.1991). "The burden then shifts to the employer to articulate a legitimate, nondiscriminatory reason for the challenged action." Id. If the employer satisfies this burden, then the plaintiff must prove that the articulated reason is a pretext. Id. "Disparate treatment involves intentional discrimination." Id. Because "the question of an employer's intent to discriminate is a pure question of fact[,] [w]e require very little evidence to survive summary judgment[.]" Id. at 1111 (quotations omitted).