In 1999, the New York Legislature amended the state Penal Law to reflect the fact that “criminal stalking behavior” had by then “become more prevalent in New York state in recent years.” The resulting law, N.Y. Penal Law §120.45, otherwise known as the cyberstalking statute, requires in relevant part in one subsection, that the government, on behalf of the complainant, establish that the:
defendant intentionally, and for no legitimate purpose, engages in a course of conduct directed at a specific person, and knows or reasonably should know that such conduct … is likely to cause such person to reasonably fear that his or her employment, business or career is threatened, where such conduct consists of appearing, telephoning or initiating communication or contact at such person’s place of employment or business, and the actor was previously clearly informed to cease that conduct.
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