Student use of cell phone is a new area of concern in today's schools. Cell phone providers have attempted to convince parents that each child should be provided with their own cell phone for safety reasons and to stay in contact with their families. This has resulted in many students arriving at school with a cell phone, taking it to class and sending and receiving voice messages as well as text messages. In addition to disrupting instruction, some students have been caught using their cell phone to cheat on tests. Criminal charges have resulted when students sent nude pictures of themselves and others to fellow students. This has resulted in felony charges for students who send and even receive (knowingly or not) what is viewed as pornography. Schools have reacted by including bans and stipulations about student use of cell phones at school. Many codes of conduct ban cell phone use during class, while others completely ban the student possession of cell phones at school.