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State courts developed [[common law]] [[tort]]s to protect against invasions of privacy:<ref>These were based largely on an influential article on privacy by Warren and Brandeis in 1890</ref>
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State courts developed [[common law]] [[tort]]s to protect against invasions of privacy:<ref>These were based largely on an influential article on privacy by Warren and Brandeis in 1890.</ref>
    
* intrusion into someone's seclusion
 
* intrusion into someone's seclusion
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