What is the test for an invasion of privacy cause of action under the common law tort of intrusion?

An invasion of privacy cause of action under the common law tort of intrusion contains similar standards: "A privacy violation based on the common law tort of intrusion has two elements. First, the defendant must intentionally intrude into a place, conversation, or matter as to which the plaintiff has a reasonable expectation of privacy. Second, the intrusion must occur in a manner highly offensive to a reasonable person." (Hernandez v. Hillsides, Inc., supra, 47 Cal.4th 272, 286.) "As to the first element of the common law tort, the defendant must have 'penetrated some zone of physical or sensory privacy . . . or obtained unwanted access to data' by electronic or other covert means, in violation of the law or social norms. [Citations.] In either instance, the expectation of privacy must be 'objectively reasonable.' [Citation.] In Sanders v. American Broadcasting Companies (1999) 20 Cal.4th 907 . . . this court linked the reasonableness of privacy expectations to such factors as (1) the identity of the intruder, (2) the extent to which other persons had access to the subject place, and could see or hear the plaintiff, and (3) the means by which the intrusion occurred." (Henderson, at pp. 286-287.)

Page 12