Corey had read in the newspaper about a local robber, referred to as "Roy the Robber," who flashed a camera at his victim to disorient him or her before taking the victim's purse or wallet. Cory decided to play a practical joke on Glenda, the author of the article, by using his flash to surprise her as she headed to her car after work. Glenda was terrified that she was the next victim. Glenda can pursue a claim against Corey for _____.