California, United States of America
The following excerpt is from Bornemann v. Gamboa, E055494 (Cal. App. 2013):
Additionally, the conduct must evidence a continuity of purpose, and comprise more than one event which seriously alarms, annoys or harasses the plaintiff. (Leydon v. Alexander (1989) 212 Cal.App.3d 1, 4.) A single incident is insufficient to meet the statutory requirement of a "course of conduct." (Ibid.)
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