Erin Andrews, the ESPN reporter unknowingly videotaped naked in a hotel room, is not the first victim of so-called video voyeurs, but according to other victims, few states have laws to protect their rights.
The video of Andrews, 31, posted online last week has become an Internet sensation. Searches for the clip -- since removed from most video sharing sites but which continues to live in a cached version on the Web -- topped Google's most searched items for two days.
"We are focused on putting this predator behind bars. This conduct is unacceptable in a civilized society," Andrews' lawyer, Marshall B. Grossman, told "Good Morning America."
For now, however, investigators do not even know who "this predator" is. Furthermore, the hotel and its location remain unknown, making the search for the perpetrator even more difficult.
It is unclear if the video was shot through a specially made hole in a wall or door, or through the hotel door's peephole.
A cached clip found by ABC News, but of unconfirmed authenticity, shows grainy images of a naked woman whom the camera seems to be following, indicating the camera may be handheld.
If investigators are able to find the Peeping Tom behind the camera, there still might be a question of whether he can be prosecuted.
Laws banning video voyeurism vary from state to state.
While a host of technological devices, from cell phones to tiny cameras, make videotaping easy, prosecuting these crimes in some places is still difficult.
Erin Andrews Video Hard to Prosecute
Susan Wilson of Louisiana knows firsthand the harm this kind of peeping can cause. In the late 1990s, she discovered she was being spied on by her neighbor.
But greater than the shock of learning her neighbor had been videotaping her was the shock that came when Wilson learned there were no laws to protect her.
"I felt victimized not only by the perpetrator but also by the fact that there were no laws to protect me. I did feel victimized twice," she told "GMA."
Wilson's story was turned into a Lifetime Television movie in 2002, spurring a series of states to enact video voyeurism laws.
Today, 19 states have laws that ban surreptitiously recording someone without that person's consent.