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concurring); See infra Part II.A.2.b for an examination of the Ellison decision. rec/ (reporting a bullying incident in a societal context). 3. See generally PETER RANDALL, BULLYING IN ADULTHOOD 7-31 (2001) (providing an overview of adult bullying); BULLYING IN AMERICAN SCHOOLS: A SOCIAL-ECOLOGICAL PERSPECTIVE ON PREVENTION AND INTERVENTION 1-5 (Dorothy L. Espelage & Susan M. Swearer eds., 2004) (providing a socialecological framework of bullying among children). 4. See discussion infra Part III. [Vol. 8 1.Student-on-Student There are two high-profile examples of student-on-student cyberbullying. One case involved eight teens in Florida who physically assaulted another student and videotaped the incident, posting it on YouTube. The students apparently wanted to gain notoriety and fame from the video, which became popular enough to obtain the attention of The New York Times.' The beating, which went on for about a half hour, left the victim with a concussion and two black eyes, and the video went viral on the Internet. The police believed that the beating was the result of comments that the victim, Victoria Lindsay, had been posting on MySpace. 9 This case is an interesting hybrid between cyberbullying, where the harassment takes place online, and traditional bullying, where the harm from the bully is physical in nature. Another interesting cyberbullying case from New York involved a middle school blogger who dubbed herself "Miss In the Know" (also known as Miss ITK) and blogged about her classmates on the Upper East Side of Manhattan. 1 " The student's blog was based heavily on the premise of the popular television show "Gossip Girl," in which an unknown resident of the Upper East Side blogs about wealthy high school students. The blog's writing style was sharp enough to merit comments from New York Magazine's Daily Intel blog 11 and The New York Sun, but students and parents were less than thrilled. One post read: "He fell so fast, even seventh graders won't hook up with him. Now that's GOTTA hurt. Dear Tommy, rip up those tickets to the top, because you're headed on a one-way trip to the B-list. Love, ITK." 12 When school officials received complaints 8.
concurring); See infra Part II.A.2.b for an examination of the Ellison decision. rec/ (reporting a bullying incident in a societal context). 3. See generally PETER RANDALL, BULLYING IN ADULTHOOD 7-31 (2001) (providing an overview of adult bullying); BULLYING IN AMERICAN SCHOOLS: A SOCIAL-ECOLOGICAL PERSPECTIVE ON PREVENTION AND INTERVENTION 1-5 (Dorothy L. Espelage & Susan M. Swearer eds., 2004) (providing a socialecological framework of bullying among children). 4. See discussion infra Part III. [Vol. 8 1.Student-on-Student There are two high-profile examples of student-on-student cyberbullying. One case involved eight teens in Florida who physically assaulted another student and videotaped the incident, posting it on YouTube. The students apparently wanted to gain notoriety and fame from the video, which became popular enough to obtain the attention of The New York Times.' The beating, which went on for about a half hour, left the victim with a concussion and two black eyes, and the video went viral on the Internet. The police believed that the beating was the result of comments that the victim, Victoria Lindsay, had been posting on MySpace. 9 This case is an interesting hybrid between cyberbullying, where the harassment takes place online, and traditional bullying, where the harm from the bully is physical in nature. Another interesting cyberbullying case from New York involved a middle school blogger who dubbed herself "Miss In the Know" (also known as Miss ITK) and blogged about her classmates on the Upper East Side of Manhattan. 1 " The student's blog was based heavily on the premise of the popular television show "Gossip Girl," in which an unknown resident of the Upper East Side blogs about wealthy high school students. The blog's writing style was sharp enough to merit comments from New York Magazine's Daily Intel blog 11 and The New York Sun, but students and parents were less than thrilled. One post read: "He fell so fast, even seventh graders won't hook up with him. Now that's GOTTA hurt. Dear Tommy, rip up those tickets to the top, because you're headed on a one-way trip to the B-list. Love, ITK." 12 When school officials received complaints 8.
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