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More than one million women report being stalked every year. Given the number of cases that likely go unreported, the number is no doubt even higher. While online stalking -- or cyberstalking -- still remains a somewhat understudied crime, the number of reports related to online harassment are increasing. The effects of stalking on the victim are significant. Victims experience anxiety, insomnia, social dysfunction and depression. They are also more likely to be victims of physical violence and homicide. A full 85 percent of female attempted homicide victims were stalked prior to being attacked.

Earlier this month in the 8-1 decision Elonis v. United States, the United States Supreme Court rejected the standard used by the overwhelming majority of appellate courts in prosecuting federal cyberstalking crimes. In so doing, the Court made it harder for victims of online threats to achieve justice.

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