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In some instances, the victims, usually teenage girls, receive as many as 40 texts a day with negative messages from their partner.
"She is required to keep her cell phone on all day, all night and be receptive," Murray explains.
The humiliation can be lasting for a teenager, said Parry Aftab, founder of the internet bullying advocacy group, Wired Safety.
The Family Violence Prevention Fund is working with the Department of Justice to release a series of public service announcements in their "That's Not Cool" campaign, which encourages teens to be more watchful of their digital relationship behavior.