Common rules for e-mail[9] and USENET such as avoiding flamewars and spam are constant across most mediums and communities. Another rule is to avoid typing in ALL CAPS, which is considered shouting or yelling. Other commonly shared points, such as remembering that one's posts are (or can easily be made) public, are generally intuitively understood by publishers of web pages and posters to USENET, although this rule is somewhat flexible depending on the environment. On more private protocols, however, such as email and SMS, some users take the privacy of their posts for granted. One-on-one communications, such as private messages on chat forums and direct SMSes, may be considered more private than other such protocols, but infamous breaches surround even these relatively private media. For example, Paris Hilton's Sidekick PDA was hacked in 2005, resulting in the publication of her private photos, SMS history, address book, etc.[10]
