1. The California statute is codified at Cal. Penal Code 646.9. See generally, Tatia Jordan, The Efficacy of the California Stalking Law: surveying its evolution, extracting insights from domestic violence cases, 6 Hastings Women’s L.J. 363 (1995). Most recently, there has been concern about the applicability of stalking statutes to Internet use. While a number of states have explicitly defined stalking to include electronic stalking (e.g., California), only North Carolina has enacted a separate cyberstalking crime law, N.C. Gen. Stat. 14-196.3.