Trespass to land is today the illicit act most often associated with the notion of transgression; it has the form of “misrepresentation in the own property rights over [real property].”   As a general rule, there is no need to interfere with an owner`s protected interest; Responsibility for involuntary infringement varies depending on jurisdiction. “[T]he Common Law, any unauthorized entry on the floor of another was an offender”; However, in the context of the non-enrichment situation brought by the Restatement of Torts, liability for involuntary interventions can only be incurred in circumstances of negligence or where trespassing is a highly dangerous activity.  By the mid-14th century, the secretaries of the royal courts were systematically beginning to distribute entries allowing an applicant to bring an infringement action. Prior to this period, criminal penalties for offences were more frequent. The courts have focused on penalizing the offence rather than compensating the landowner. From the outset, an accused convicted of an offence was fined; an accused who was unable to pay the fine was incarcerated. The fine imposed in connection with this criminal proceeding turned into an action for damages against the applicant. This change marked the beginning of an unauthorized act under the common law. In recent years, in the United States, the immaterial non-ownership of Chattels has been expanded, including the fight against the dissemination of unwanted mass emails and virtual real estate interests in online worlds. In the late 1990s, U.S. courts increased the offence of Chattels to include first the unauthorized use of telephone lines and subsequently unsolicited mass e-mails.
 In 1998, a federal court in Virginia found that the owner of a marketing company had breached an Internet service provider`s computer network by sending 60 million unauthorized electronic advertisements after being informed that spam was not allowed.  In America Online, Inc. against LCGM, Inc., AOL successfully sued a pornographic site to spam AOL customers and forge the AOL domain name in order to deceive customers.