In a Pennsylvania case, the victim's verbal protest against penetration was not enough for State prosecutors to win a rape conviction. In a New Jersey case, lack of consent to intercourse was sufficient to lead to a finding of criminal sexual assault. Evidence in a California case that the defendant's behavior generated fear in the victim helped win a rape conviction. Despite their differences, State rape statutes generally provide that the crime of rape can be established if there is evidence of three elements: (1) that sexual activity occurred between the defendant and the victim; (2) that the defendant used force or the threat of force to engage in sexual activity; and (3) that the victim did not consent to sexual activity. There is widespread confusion and disagreement, however, over the meaning of these three elements and their relative importance. States have even developed their own statutory terms for sex offenses, a trend that legal experts say is designed to rid sex crimes of specific "resistance and proof" connotations. Several States, including Minnesota and Utah, do not require evidence of force to prosecute and convict on a rape charge. Moreover, States treat consent and resistance differently. Recent court rulings in Pennsylvania, California, and New Jersey highlight difficulties associated with interpreting sexual assault statutes.