An appropriate legal definition of "stalking" is "a knowing, purposeful course of conduct directed at a specific person that would cause a reasonable person to fear bodily injury or death to himself or herself or a member of his or her immediate family." Although the study of stalking is still in its infancy, several authorities have begun to classify stalkers according to certain characteristics. Holmes reviewed some of the current relevant literature and identified six types of stalkers based on their victims. The "celebrity stalker" usually targets someone in the entertainment field; the "lust stalker" is motivated by sex and will stalk one victim after another in a serial fashion; the "hit stalker" is the paid professional killer who follows his prey to establish habits and then kills for profit; the "love-scorned stalker" intends to frighten or injure the victim, who has usually rejected him/her; the "domestic stalker" is the former spouse, girlfriend, or boyfriend of the victim; and the "political stalker" targets an appointed or elected official. Geberth established a typology of stalkers based on their mental status. This approach focuses on the mental state of the stalker rather than the victim of the stalker. Geberth classified stalkers into two types: the "psychopathic personality" stalker and the "psychotic personality" stalker. Restraining orders or protective orders are court orders that prohibit the offender from having any contact with the victim. Police and lawyers most often recommend that victims obtain restraining orders, because they obligate the criminal justice system to hold offenders accountable once they are restricted by the order. Restraining orders are effective when the stalker is rational and can control his/her behavior to avoid legal consequences. They are ineffective when the stalker has little regard for the consequences of stalking behavior and is obsessed with harming or harassing the victim. Enforcement mechanisms for restraining orders are also limited. 19 references