Two teenage girls were arrested in Florida and charged with cyberstalking after creating a fake Facebook page impersonating another student and using it to bully her. Students at an Indianapolis high school set up false Twitter accounts for their principal and tweeted offensive comments before the account was shut down. And at a Minnesota middle school, someone created a false Facebook profile for a 6th grader and used it to make violent threats. Students' creation of fake online identities is forcing schools to deal with such behavior, which raises legal as well as school safety concerns. In fact, some behavior in such situations can now be deemed illegal under state cyberbullying laws or even cyber-impersonation and identity-theft laws. Thirty-eight states have bullying laws that include a ban on "electronic harassment" in their provisions, and 14 states have laws that expressly prohibit cyberbullying, according to the Cyberbullying Research Center, which tracks such legislation. Some states, such as New Jersey, also have identity-theft laws that have been used in cases involving fake social-networking profiles, and California, New York, and Texas all have laws against cyber or digital impersonation. While cyberbullying is often just an electronic form of such traditional bullying techniques as spreading rumors and teasing, "online impersonation is one of those new, creative ways to be really hurtful."