Rose Hunter
Law and the Internet
Professor Wiseman
Georgia State University College of Law
Fall 2001
TABLE OF CONTENTS
I. Introduction
A. Federal
ii. 47 U.S.C. 223
iii. 18 U.S.C. 2261A
iv. 18 U.S.C. 2425
B. State
1. Alabama
2. Alaska
3. Arizona
4. Arkansas
5. California
6. Colorado
7. Connecticut
8. Georgia
9. Illinois
10. Indiana
11. Iowa
12. Maine
13. Maryland
14. Massachusetts
15. Michigan
16. Minnesota
17. Missouri
18. New Hampshire
19. New York
20. North Carolina
21. Ohio
22. Oklahoma
23. Oregon
24. Pennsylvania
25. Rhode Island
26. South Dakota
27. Texas
28. Vermont
29. Virginia
30. Washington
31. Wisconsin
32. Wyoming
1. Florida
2. Hawaii
3. Kansas
4. Louisiana
5. New Jersey
7. Tennessee
III. How do you protect yourself
IV. Conclusion
I. INTRODUCTION
A. Definition of Cyberstalking
Cyberstalking occurs when electronic mediums such as the Internet are used to pursue, harass or contact another in an unsolicited fashion. [1] [2] Many stalkers are motivated by a desire to exert control over their victims.[3]
B. Where does cyberstalking occur?
The online user is vulnerable in primarily three areas.[4] The areas include live chat or Internet relay chat lines, message boards or newsgroups and the users e-mail box.[5]
Live Chat
Live chat harassment occurs when the victim is sabotaged electronically.[6]
An example is flooding the victim's Internet chat channel to disrupt their conversation.[7]
Message Boards
A cyberstalker can dupe other users into harassing or threatening a victim by
using message boards.[8] For example, a cyberstalker
could post a controversial or enticing message on the board under the name,
phone number, or e-mail address of the victim, resulting in responses being
sent to the victim.[9]
E-Mail
A cyberstalker may send repeated, threatening or harassing messages to the victims
e-mail box. [10]
A. Federal
Under this statute it is a federal crime punishable by up to five years in prison and a fine of up to $25,000 to transmit any communication in interstate or foreign commerce containing a threat to injure another. [11] Section 875(c) includes threats transmitted in interstate or foreign commerce via e-mail or the Internet.[12]
This statute is not an all-inclusive anti-cyberstalking statute. [13] It applies only to communications of actual threats, therefore it would not apply in a situation where a cyberstalker is engaged in a pattern of conduct intended to harass or annoy another but with no threat.[14] It is also not clear whether it would apply where a person harasses or terrorizes another by posting messages on a message board duping others to harass or annoy another.[15]
A provision of this statute provides that anonymous use of a telecommunications device to annoy, abuse, harass, or threaten any person is a federal crime, punishable by up to two years in prison. [16] The statute also requires that the perpetrator not reveal his name.[17]
This statute is broader than 18 U.S.C. 875 because it covers both threats and harassment.[18] Section 223 only applies to direct communications between the perpetrator and the victim, therefore it would not reach a situation where a person harasses or terrorizes another person by posting messages on a bulletin board or in a chat room encouraging others to harass or annoy another person.[19]
This statute makes it a crime for any person to travel across state lines with the intent to injure or harass another person and places that person in a reasonable fear of death or serious bodily injury.[20]
The requirement that the stalker physically travel across state lines makes it largely inapplicable to cyberstalking cases.[21]
This statute makes it a federal crime to use any means of interstate or foreign commerce to knowingly communicate with any person with the intent to solicit or entice a child into unlawful sexual activity.[22]
This statute does not reach harassing communications to minors absent a showing of intent to entice or solicit the child for illicit sexual purposes.[23]
This bill revises the stalking provisions of the Federal criminal code to prohibit a person, with the intent to kill or injure a person in another state or to put such person in reasonable fear of death or bodily injury, from using or causing another to use any facility of interstate or foreign commerce to place that person in reasonable fear of death or serious injury to the person.[24]
There are 33 cyberstalking laws on the books. Eight states have legislation pending, however nine states have no statutes regarding these crimes.[25]
The states with cyberstalking statutes include Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Georgia, Illinois, Indiana, Iowa, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, New Hampshire, New York, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Dakota, Texas, Vermont, Virginia, Washington, Wisconsin, and Wyoming. The states with cyberstalking legislation pending include Florida, Hawaii, Kansas, Louisiana, New Jersey, South Carolina, Tennessee and West Virginia. The states with no cyberstalking legislation include Idaho, Kentucky, Mississippi, Montana, Nebraska, Nevada, New Mexico, North Dakota, and Utah.[26] The provisions of the above statutes are as follows:
Cyberstalking Legislation States
Alabama's harassing communications statute provides that a person commits a crime when that person, with the intent to harass or alarm another person, communicates with a person anonymously or otherwise, by electronic communication, in a manner likely to harass or cause alarm. [27] This statute appears to encompass all types of cyberstalking, however, it is unclear whether it would apply where a person harasses another by posting messages on a message board duping others to harass or annoy another.
This statute provides that it is a crime to have nonconsensual contact with another person.[28] Nonconsensual contact includes sending electronic communications to a person when it is initiated or continued without that person's consent, that is beyond the scope of the consent provided by that person, or that is in disregard of that person's expressed desire that the contact be avoided or discontinued.[29] It is unclear if this statute prohibits the use of message boards to entice others to send messages to another.
This statute provides that a person commits harassment if he has intent to harass or has knowledge that he is harassing another person and he anonymously or otherwise communicates or causes a communication with another person by electronic means in a manner that harasses.[30] This statute appears to be all-inclusive because it covers not only harassment initiated and sent by the perpetrator, but it also includes harassment that may not be sent by the perpetrator, but nonetheless was caused by the perpetrator.
The Arkansas statute provides that a person commits the offense of unlawful computerized communications if he sends a message to the person and that message threatens to cause physical injury to any person or damage to the property of any person or that message uses obscene, lewd, or profane language, and he has the intent to frighten, intimidate, threaten, or harass the person.[31] This statute appears to be limited to threats and obscene language. It is unclear whether or not harassing electronic communications lacking these two elements would fall under this statute. It is also unclear whether or not this statute would include electronic communications that were not sent by the perpetrator but that were caused to be sent by the perpetrator.
This statute provides that a person is guilty of cyberstalking when the person willfully, maliciously, and repeatedly harassed another person and makes a credible threat with the intent to place the person in reasonable fear of his or her safety or the safety of their immediate family.[32] This statute clearly limits the crime with the requirement of a threat. This statute would not cover electronic communications that are harassing, but do not include a threat. It is also unclear whether or not this statute would include electronic communications that were not sent by the perpetrator but that were caused to be sent by the perpetrator and the communication included a threat.
This statute provides that a person commits harassment when he, with the intent to harass, annoy, or alarm another person, initiates communication anonymously or otherwise by computer, computer network, or computer system in a manner intended to harass or threaten bodily injury or property damage or makes an obscene request.[33] This statute appears to be all-inclusive, covering live chat harassment, message board harassment and e-mail harassment.
This statute provides that a person is guilty of harassment when he, with the intent to harass, annoy, or alarm another, communicates with a person by computer network in a manner likely to cause annoyance or alarm.[34] This statute appears to be all-inclusive, covering live chat harassment, message board harassment and e-mail harassment.
Under Georgia law a person commits the offense of stalking when he communicates with another person by computer, computer network, or any other electronic device, which causes emotional distress by placing such person in reasonable fear of his safety or the safety of his immediate family.[35] It appears that this statute is not all-inclusive because of the requirement that the victim be in reasonable fear of his safety. This would not include communications that are harassing but not threatening.
Under this statute a person commits cyberstalking when he, on at least two separate occasions, harasses another person through the use of electronic communication.[36] The person must transmit a threat of bodily harm, sexual assault, confinement or restraint, or place that person in reasonable apprehension of bodily harm, sexual assault, confinement, or restraint.[37] It appears that this statute is not all-inclusive because of the requirement that the victim be in reasonable fear of his safety. This would not include communications that are harassing but not threatening.
This statute provides that a person commits harassment when he uses a computer network or other form of electronic communication to communicate with a person or transmit an obscene message or indecent or profane words to a person.[38] The person must have the intent to harass, annoy, or alarm another.[39] It appears that this statute is not all-inclusive because of the requirement that the message be obscene or indecent. This would not include communications that are harassing but not obscene or indecent. The extent of the statute would depend on the court's interpretation of obscene and indecent.
The Iowa statute provides that a person commits harassment when the person has the intent to intimidate, annoy, or harm another person and communicates with another person over the Internet without legitimate purpose and in a manner likely to cause the other person annoyance or harm.[40] This statute is unclear whether or not communications that are caused by the perpetrator is included in the crime of harassment.
Maine's statute provides that the crime of stalking includes communicating by electronic means with a person with the intent to harass, annoy or alarm that person.[41] This appears to be all-inclusive, however this statute is unclear whether or not communications that are caused by the perpetrator is included in the crime of harassment.
This statute provides that a person may not use electronic mail for a communication made with intent to harass a person by sending, lewd, lascivious, or obscene material.[42] It appears that this statute limits the crime and would not include communications that do not include lewd, lascivious, or obscene material but is otherwise harassing. This statute is also unclear whether or not communications that are caused by the perpetrator is included in the crime of harassment.
Massachusetts' statute provides that a person is guilty of stalking when, through electronic mail or internet communications, he willfully and maliciously engages in a pattern of conduct which alarms or annoys that person and would cause a reasonable person to suffer emotional distress and makes a threat with the intent to place the person in eminent fear of death or bodily injury.[43] This statute limits the crime of stalking and would not include harassing communications unless it includes a threat. This statute is also unclear whether or not communications that are caused by the perpetrator is included in the crime of harassment.
Under this statute a person is guilty of a crime when that person sends electronic communications to an individual that is continued without that individuals consent or in disregard of that individual's expressed desire that the contact by avoided or discontinued.[44] This statute appears to include most types of cyberstalking, but it is not clear whether or not it would include message board harassment.
Under this statute a person who repeatedly sends electronic mail that the person knows or has reason to know would cause the victim to feel frightened, threatened, oppressed, persecuted, or intimidated and causes this reaction on the part of the victim.[45] This statute appears to require the inclusion of some threatening language in the communication, but is unclear. This statute is also unclear whether or not communications that are caused by the perpetrator is included in the crime of harassment.
In New Hampshire a person is guilty of a misdemeanor when he sends electronic mail with the purpose to annoy or alarm another, having been previously notified that the recipient does not desire further communications, communicates with that person, when the communications is not for a lawful purpose or constitutionally protected.[46] This statute appears to be intended to police the use of spam. However, it appears that the statute covers most of the types of cyberstalking, but it is unclear if it would cover message board harassment.
The New York statute provides that a person is guilty of aggravated harassment when the person has the intent to harass, annoy, threaten or alarm another and the person communicates or causes a communication to be initiated by electronic means with another person in a manner likely to cause annoyance or alarm.[47] It appears that this statute is all inclusive, including live chat harassment, message board harassment and e-mail harassment.
Under this statute it is unlawful for a person to use any words or language threatening to inflict bodily harm to any person or for the purpose of extorting money or other things of value from any person in electronic mail or electronic communication.[48] It is unlawful for a person to electronically mail or electronically communicate to another repeatedly for the purpose of abusing, annoying, threatening, terrifying, harassing or embarrassing any person.[49] This statute appears to cover all types of harassment sent by the perpetrator, however, it is not clear whether the statute includes message board harassment where the perpetrator does not actually send the harassing communications but causes the communications to be sent.
Under this statute a person shall not send electronic mail with the intent to harass or abuse any person, or communications with sexual content and the person has requested that the sender not make the communication.[50] This statute appears to cover all types of harassment sent by the perpetrator, however, it is not clear whether the statute includes message board harassment where the perpetrator does not actually send the harassing communications but causes the communications to be sent.
Under this statute it is unlawful to use a computer, computer system, or computer network to annoy, abuse, threaten, or harass another person or to put another person in fear of physical harm or death.[51] This statute appears to cover all types of harassment sent by the perpetrator, including message board harassment where the perpetrator does not actually send the harassing communications but causes the communications to be sent.
Under this statute it is a misdemeanor to transmit any communication by computer to any person repeatedly for the sole purpose of harassing or annoying another.[52] It is also a crime to use any threatening, vulgar, indecent, or obscene language.[53] This statute appears to cover all types of harassment sent by the perpetrator, however, it is not clear whether the statute includes message board harassment where the perpetrator does not actually send the harassing communications but causes the communications to be sent.
Under this statute any person who willfully, maliciously, and repeatedly harasses another person by means of electronic communication is guilty of the crime of stalking.[54] This statute appears to cover all types of harassment sent by the perpetrator, however, it is not clear whether the statute includes message board harassment where the perpetrator does not actually send the harassing communications but causes the communications to be sent.
Under this statute a person is guilty of disturbing the peace when he, with intent to terrify, threaten, harass or annoy, makes contact by means of electronic communication with another and makes any request that is obscene, lewd or indecent.[55] It is also a crime to threaten to inflict injury or physical harm to the person or property of any person.[56] It appears that this statute limits the crime of cyberstalking by requiring an obscene, lewd or indecent request. It is also not clear whether the statute includes message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
The Virginia statute provides that a person is guilty of a misdemeanor if that person has the intent to coerce, intimidate or harass any person and the person uses a computer or computer network to communicate obscene language or threaten any illegal or immoral act.[57] It appears that this statute limits the crime with its requirement of obscene language or threat of an illegal or immoral act. However, it does appear to cover message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This statute provides that a person is guilty of harassment if the person sends an electronic communication and knowingly threatens to cause bodily injury or cause property damage, or subject that person to physical confinement.[58] This statute limits the scope of the crime to communications including threats. It is not clear whether the statute includes message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This statute provides that it is unlawful to send electronic mail or other computerized communications with the intent to frighten, intimidate, threaten, abuse or harass another and threaten to inflict injury or send a message that uses obscene, lewd or profane language.[59] The use of this statute is limited by the requirement of a threat or obscene, lewd, or profane language. It is not clear whether the statute includes message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This statute provides that a person commits the crime of stalking if he communicates electronically with another person in a manner the person should have known would cause a reasonable person emotional distress.[60] The use of this statute is limited by the requirement that a person experience emotional distress. Beyond that, it appears to include most all types of communications sent by the perpetrator. However, it is unclear whether the statute includes message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This bill defines the term cyberstalk to mean communications by means of e-mail or electronic communication that causes substantial emotional distress and does not serve a legitimate purpose.[61] This definition appears to include all types of cyberstalking, including message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This bill makes the unlawful use of computerized communication systems for the purpose of harassing another person a misdemeanor, and makes the sender's property subject to forfeiture.[62] This bill appears to include all types of cyberstalking, including message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This bill includes computer electronic mail, computer Internet or Internet services, and computer bulletin board services or other electronic forms of communication as "cause of conduct" in the Kansas stalking statute.[63] This bill redefines the phrase "cause of conduct" to encompass all types of cyberstalking. It appears that it includes message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This bill redefines the crime of stalking to include electronic mail.[64] A second bill adds the making of a credible threat to the crime of stalking, including those made through electronic communication.[65] It appears that the use of this bill would be limited to cyberstalking that includes a threat, and it is unclear if the statute includes message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This act adds electronic mail messages as a method by which a person may commit the crime of harassment and prohibits the use of electronic mail to send obscene or indecent commercial messages.[66] It appears that this bill encompasses most types of cyberstalking, however, its is unclear whether the bill includes message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This act criminalizes the use of the Internet and other electronic communication devices to commit harassment or stalking.[67] This bill appears to include all types of cyberstalking, including message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This bill specifies that electronic communication is contact for purposes of stalking and includes electronic threats within the crime of harassment.[68] The use of this bill as a statute is limited by the requirement of a threat. It is unclear whether message board harassment would be included in the scope of the definition of the statute.
This bill amends the meaning of communication within the stalking statute to include electronic means including electronic mail and the Internet.[69] This bill appears to include all types of cyberstalking, including message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This bill includes electronic communications within the definitions of harassment.[70] This bill appears to include all types of cyberstalking, including message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
This bill includes electronic communications including electronic mail or Internet services within the definitions of stalking.[71] This bill appears to include all types of cyberstalking, including message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
The purpose of this bill is to strengthen the stalking law to include harassment by computer.[72] This bill appears to include all types of cyberstalking, including message board harassment where the perpetrator does not actually send the harassing communication but causes the communications to be sent.
Screen Name
Do not use your real name or nickname as your screen name or user ID.[73] Use a gender-neutral email address.[74] Do not send unwanted signals by having an email address such as "sexygal@domain.com." People judge your character and purpose online by your username.[75]
Password
Use a password that has no relation you as a person; use a combination of symbols, numbers and letters and make sure it is at least six characters long.[76] Never give out your password and try not to write it down. Avoid using the same password for multiple accounts.[77]
User Profile
Do not post personal information as part of user profiles.[78] Look up your username and domain and obtain information on your file by using "Finger".[79] Change information you do not want others to see. You can try a Finger search by visiting http://www.rickman.com/finger.html or http://www-bprc.mps.ohio-state.edu/cgi-bin/finger.pl. [80]
Signature and Header
If your e-mail software allows you to attach a signature or header to your mail, they may provide information to others that you do not want distributed.[81] Make sure your signature or header does not give away your home telephone number or any other personal details.[82]
E-Mail Accounts
Use your primary account only for messages to and from people you know and trust.[83] Use a free e-mail account for all other online activities.[84] Consider using encryption to protect your e-mail messages.[85] Encryption is a program that can prevent someone from impersonating you. Visit http://www.well.com/user/abacard/pgp.html for more information on this program.[86]
News Groups and Chatting
When you post to a news group or bulletin board many postings are stored in archives and can be accessed for months enabling cyberstalkers to trace you.[87] Consider using an anonymous re-mailer to post messages to these sites.[88] When chatting or using instant messaging set your options to block all users except those on your buddy list.[89]
Web Browsing
Websites currently log your web surfing and all your information.[90] Consider using an anonymous web browser so that no one will be able to pick up any information about you. Visit http://www.anonymizer.com to learn more about this service.[91] If you are making a purchase through a web site, make sure it is secure before you give you credit card information.[92] No reputable merchant will ask you for your mother's maiden name and social security number for verification. If you are asked for this information, BEWARE, it may be part of a scam.[93]
Meeting On-Line Acquaintances in Person
Be extremely cautious about meeting on-line acquaintances in person.[94] If you decide to meet, bring a group of friends and meet during the day in a public place.[95] Keep your on-line interaction in the open so other people can look out for you.[96]
Education
The more you know about the equipment you are using on the Internet the less likely you to fall prey to online harassment.[97] Cyberstalkers target beginners because they are less likely to know what to do.[98] Read and study all information on technology.[99]
IV. CONCLUSION
In the end, there are only thirty-three states with cyberstalking laws on the books. Eight states are attempting to address the issue with bills pending in the legislature, but nine states have yet to bring the issue to the table. Why have the States waited so long to enact laws prohibiting cyberstalking on the Internet? Is it a sign that States are not taking cyberstalking seriously? Cyber law is a young area of law and at times the connection between "cyberspace" and "reality" can be hard to find. It is through education and awareness that legislators will bring the issue of cyberstalking to the forefront of their agendas.
While there are many States that have enacted cyberstalking statutes, many of the statutes do not encompass broad enough elements to include all types of cyberstalking. Many States limit the ability to prosecute under these statutes by requiring threatening or crude and obscene language. Other States limit the ability to prosecute under these statutes by requiring the harassing communications to be sent directly by the perpetrator, leaving victims of harassing e-mail from message boards with falsified postings with no recourse against the perpetrator.
The Federal government has also attempted to put laws on the books that would make cyberstalking a federal crime. These statutes, like the various States' statutes, are limited in their ability to capture all types of cyberstalking under their strict requirements. These statutes need to be evaluated to determine how they can be amended to better serve the needs of people who are victims of Internet harassment.
ENDNOTES
[1] http://www.crimelibrary.com/criminology/cyberstalking/; "Cyber-Stalking: Obsessional Pursuit and the Digital Criminal," last visited 10/16/91 (Back)
[2] Cyberstalking is an extension of the physical form of stalking. Id. (Back)
[3] http://cyberguards.com/CyberStalking.html; "Cyberstalking," last visited 10/16/01 (Back)
[4] http://www.ucalgary.ca/~dabrent/380/webproj/jessica.html; "Cyberstalking Awareness and Education," last visited 10/16/01 (Back)
[5] Id. (Back)
[6] Id. (Back)
[7] Id. (Back)
[8] http://cyberguards.com/CyberStalking.html; "Cyberstalking," last visited 10/16/01 (Back)
[9] Id. (Back)
[10] Id. (Back)
[11] 18 U.S.C. 875(c) (Back)
[12] Id. (Back)
[13] http://cyberguards.com/CyberStalking.html; "Cyberstalking," last visited 10/16/01 (Back)
[14] Id. (Back)
[15] Id. (Back)
[16] 47 U.S.C. 223 (Back)
[17] 47 U.S.C. 223(a)(1)(c) (Back)
[18] http://cyberguards.com/CyberStalking.html; "Cyberstalking," last visited 10/16/01 (Back)
[19] Id. (Back)
[20] 18 U.S.C. 2261A (Back)
[21] http://cyberguards.com/CyberStalking.html; "Cyberstalking," last visited 10/16/01 (Back)
[22] 18 U.S.C. 2425 (Back)
[23] http://cyberguards.com/CyberStalking.html; "Cyberstalking," last visited 10/16/01 (Back)
[24] U.S. Senate Bill 2991, 106th Congress (Back)
[25] http://www.haltabuse.org/resources/laws/index.shtml; "Working to Halt Online Abuse," last visited 11/15/01 (Back)
[26] Id. (Back)
[27] Alabama Code Annotated §13A-11-8 (Back)
[28] Alaska Code Annotated §11-41-260 (Back)
[29] Id. (Back)
[30] Arizona Code Annotated §13-2921 (Back)
[31] Arkansas Code Annotated §5-41-108 (Back)
[32] California Penal Code §4-646.9 (Back)
[33] Colorado Code Annotated §18-9-111 (Back)
[34] Connecticut Code Annotated §53a-183 (Back)
[35] Official Code of Georgia Annotated §6-5-90(G) (Back)
[36] Illinois Code Annotated §5-12-7.5 (Back)
[37] Id. (Back)
[38] Indiana Code §35-45-2-2 (Back)
[39] Id. (Back)
[40] Iowa Code Annotated §708.7 (Back)
[41] Maine Code §210-A(2) (Back)
[42] Maryland Code Annotated §555C (Back)
[43] Massachusetts Code §265-43 (Back)
[44] Michigan Code §750-411(h) (Back)
[45] Minnesota Code §609-749 (Back)
[46] New Hampshire Code §644-4 (Back)
[47] New York Code Annotated §240.30 (Back)
[48] North Carolina Code §14-169.3 (Back)
[49] Id. (Back)
[50] Ohio Code §2917-21 (Back)
[51] Oklahoma Code §21-70-1953 (Back)
[52] Rhode Island Code §11-52-4.2 (Back)
[53] Id. (Back)
[54] South Dakota Code §22-19A-1 (Back)
[55] Vermont Code Annotated §1027 (Back)
[56] Id. (Back)
[57] Virginia Code Annotated §18.2-152.7 (Back)
[58] Revised Code of Washington §9A-46-020 (Back)
[59] Wisconsin Code Annotated §947-0125 (Back)
[60] Wyoming Code Annotated §6-2-506 (Back)
[61] Florida Senate Bill S960; 29-742-01 (Back)
[62] Hawaii Senate Bill 650, 2000 (Back)
[63] Kansas Bill SB595; amending K.S.A. §21-3438 (Back)
[64] Louisiana House Bill HB 553 (Back)
[65] Louisiana Senate Bill SB35 (Back)
[66] Missouri Senate Bill 255, 2001 (Back)
[67] New Jersey Assembly NO 731, 2001 (Back)
[68] Oregon House Bill 2918 (Back)
[69] Pennsylvania Bill No. 167, 1999 (Back)
[70] South Carolina Senate Bill 481 (Back)
[71] Tennessee House Bill 302 (Back)
[72] West Virginia Senate Bill 133 (Back)
[73] http://www.cyberguards.com/CyberStalking.html; "Cyberstalking," last visited 10/16/01 (Back)
[74] http://www.grafx-specs.com/News/Cybstlk2.html; "CYBERSTALKING-Part II A Real Life Problem," last visited 10/16/01 (Back)
[75] Id. (Back)
[76] http://www.sfwa.org/gateway/stalking.htm; "Cyberstalking and Internet Safety FAQ," last visited 10/16/01 (Back)
[77] Id. (Back)
[78] http://www.cyberguards.com/CyberStalking.html; "Cyberstalking," last visited 10/16/01 (Back)
[79] http://www.grafx-specs.com/News/Cybstlk2.html; "CYBERSTALKING-Part II A Real Life Problem," last visited 10/16/01 (Back)
[80] Id. (Back)
[81] http://www.crimelibrary.com/criminology/cyberstalking/6.htm; "Cyber-Stalking: Obsessional Pursuit and the Digital Criminal," last visited 10/16/01 (Back)
[82] http://www.grafx-specs.com/News/Cybstlk2.html; "CYBERSTALKING-Part II A Real Life Problem," last visited 10/16/01 (Back)
[83] http://www.infotoday.com/luju100/hitchcock.htm; "Cyberstalking," last visited 10/16/01 (Back)
[84] Id. (Back)
[85] http://www.grafx-specs.com/News/Cybstlk2.html; "CYBERSTALKING-Part II A Real Life Problem," last visited 10/16/01 (Back)
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BIBLIOGRAPHY
Cyberguards, Cyberstalking, http://www.cyberguards.com/CyberStalking.html
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Laughren, Jessica, Cyberstalking Awareness and Education, http://www.ucalgary.ca/~dabrent/380/webproj/jessica.html
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