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Counseling geriatric patients about opportunity and risk when ‘digital dating’

Baby Boomers represent a rapidly growing segment of digital device users.1 As these people age, their continued, even increasing, use of the Internet can be expected.1 At the same time, many older adults (age ≥65) are engaged in intimate relationships and regard sexuality as an important part of life.2

At this intersection, the Internet is likely to play a role in geriatric sexuality and “digital intimacy”—in that older adults can adopt patterns of using online dating sites similar to what their younger counterparts engage in. There is a need among clinicians to avoid stereotypical perceptions of “ageism” and the myth of “geriatric asexuality” as a result of older patients’ continued sexual interest and their adoption of social media technologies to facilitate the development of new intimate relationships. Acknowledgement of these realities by clinicians may assist in understanding and communication regarding these important areas of patients’ lives.


Why online dating?

Contemporary social and demographic changes (eg, higher divorce rates, increased longevity, aging of Baby Boomers) have influenced patterns of dating behaviors.3 Consistent with evolutionary theory, studies on courtship behaviors show that women remain the “choosers” of partners in relationships at all ages3; in contemporary society, however, there is an increasing ratio of women to men in later life, and the degree to which this demographic change might influence older men and women who are pursuing sexual relationships is unclear.3 Older adults might be aware of these demographic realities, and may use the Internet to increase their chances of finding a relationship.

For older homosexual men and women, demographic trends also are important because fewer available partners of similar sexual orientation might be available in their immediate communities, similarly incentivizing the use of online dating sites.


Hand in hand: Risk and vulnerability

Clinicians can discuss with geriatric patients who present with questions or concerns about sexuality and risks of online dating. Although risks associated with digital dating can involve anyone, those who are recently divorced, widowed, disabled, or elderly can be targeted by predators or fraudulent schemes, and thus become victims. Recognizing those risks and the vulnerability in the geriatric patient is crucial.

Chronic illness. Age-related physiological changes do not necessarily make one vulnerable; however, chronic diseases of aging, including major neurocognitive disorders, can impair daily function and increase disability and vulnerability. The majority of online dating sites do not discriminate among users, including those with disabilities such as incapacitating neuropsychiatric disorders. The clinician may need to assess cognitive status of patients specific to their capacity to fully understand the risks of use of social media. Inability to accomplish basic mastery of computer skills or inability to maintain appropriate boundaries and safeguards in relationships initiated and maintained using the Internet may assist in this determination. Patients with other problematic Internet use (eg, excessive devotion to online shopping or online gambling) may be prone to misusing social media and dating sites as well. Patients with clear impairment of memory or poor social judgment based on a neurocognitive disorder also might not maintain proper boundaries with social media use.

Feeling alone. Older persons might feel socially isolated, and therefore may be more willing to participate in online dating to increase their chances of establishing an intimate relationship or companionship. Research has shown that increased social ties, participation in groups, contact with friends and family, and perceived social support are associated with longer survival; on the other hand, social disengagement, low participation in leisure activities, and limited social networks are associated with higher risk of major neurocognitive disorders and increased disability.4

Little is known about social vulnerability in institutional settings, but institutional living could decrease social vulnerability in important ways (eg, access to social support, networks and activities, not living alone).4 Although the literature on older adults and “digital” or “virtual” dating is limited, there are essentially no such data from within institutional settings. It is important to separately address the issue of cognitively impaired patients’ capacity to consent to sexual activity both within institutional settings and elsewhere, as it raises numerous ethical dilemmas for clinicians.

Being sexually active. Early research into online dating focused particularly on the risks of sexually transmitted infections (STIs),5 which could be acquired through failure to use condoms with a new partner.6 Older women particularly are less likely to use condoms with new sexual partners.6 Screening at-risk adults should occur regardless of age. Effective interventions are needed to increase condom use in this age group. Research in the general population has started to investigate how the use of technology can minimize the risks associated with online dating.5 The Table5,6 lists strategies that can be used to minimize some of the risks of online dating among geriatric patients, including STIs and victimization.

 

 

Clinicians working with sexually active geriatric patients need to perform sexual risk assessments, complete capacity assessments, and provide preventive measures.


Legal issues

Criminal and civil liability issues have arisen with online dating involving cases of murder, rape, fraud, identity theft, loans, theft, domestic violence, stalking, and burglary. Online dating also raises concerns around the right to fair use of the Internet in different contexts. Flirting in cyberspace can occur with e-mail, text, Twitter, Skype, and Instant Messenger. Practices likely will vary depending on whether older adults are institutionalized or living in the community, as well as their mental status (eg, having a major neurocognitive disorder).

Some questions with legal implications worth considering include:

  • To what extent is there a duty to accommodate healthy sexual relationships in institutionalized settings?
  • At what point does monitoring and supervision become overly intrusive?
  • Are older adults fully aware of the potential ramifications of sharing sensitive information in cyberspace?
  • What is the threshold for capacity to consent among older adults to understand the sexual nature of the act and consent to the act?

Nursing homes and health care providers may become concerned about potential liability if their organization provides digital devices or electronic platforms that are not closely monitored. Clinicians have a duty to protect patients under their care from risks associated with predators who target vulnerable and lonely people, whether financially, emotionally, or physically. Some patients in nursing home settings may benefit from discussing with their family members or attorney the possibility of completing a “sexual power of attorney”7 that could be completed in conjunction with an advance health care directive that addresses or authorizes an agent to make decisions about their sexual activities if cognitively impaired in the future.

One might also consider to what extent local regulatory oversight will protect your patient. Not all jurisdictions regulate online dating services similarly; many existing regulations focus on unfair contracts and pay less heed to safety concerns.

As a result, some dissatisfied clients have been known to sue an online dating service for breach of contract or misrepresentation. One of the most significant issues, however, is making sure there are appropriate background checks. Online dating services may need to change their policies to screen and verify for criminal background checks.8 Older adults interested in online dating should be made aware of these emerging issues.


Disclosures

The authors report no financial relationship with any company whose products are mentioned in this article or with manufacturers of competing products.

References


1. Veenhof B, Timusk P. Online activities of Canadian boomers and seniors. http://www.statcan.gc.ca/pub/11-008-x/2009002/article/10910-eng.htm#tphp. Updated April 23, 2014. Accessed April 26, 2015.
2. Lindau ST, Schumm LP, Laumann EO, et al. A study of sexuality and health among older adults in the United States. N Engl J Med. 2007;357(8):762-774.
3. Alterovitz SS, Mendelsohn GA. Partner p across the life span: online dating by older adults. Psychol Aging. 2009;24(2):513-517.
4. Andrew MK, Mitnitski AB, Rockwood K. Social vulnerability, frailty and mortality in elderly people. PLoS ONE. 2008;3(5):e2232. doi: 10.1371/journal.pone.0002232.
5. Couch D, Liamputtong P, Pitts M. Online daters and the use of technology for surveillance and risk management. International Journal of Emerging Technologies and Society. 2011;9(2):116-134.
6. Bateson DJ, Weisberg E, McCaffery KJ, et al. When online becomes offline: attitudes to safer sex practices in older and younger women using an Australian internet dating service. Sex Health. 2012;9(2):152-159.
7. Hill E. We’ll always have Shady Pines: surrogate decision-making tools for preserving sexual autonomy in elderly nursing home residents. William Mary J Women Law. 2014;20(2):468-490.
8. Doe v Match.com, 789 F Supp 2d 1197, 1199 (CD Cal 2011).

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Ana Hategan, MD
Associate Clinical Professor and Geriatric Psychiatrist
Department of Psychiatry and Behavioural Neurosciences
Division of Geriatric Psychiatry
Michael G. DeGroote School of Medicine
Faculty of Health Sciences
McMaster University
Hamilton, Ontario, Canada


James A. Bourgeois, OD, MD
Clinical Professor
Department of Psychiatry
Langley Porter Psychiatric Institute
Consultation-Liaison Service
University of California
San Francisco Medical Center
San Francisco, California

Usha Parthasarathi, MBBS
Associate Clinical Professor and Psychiatrist
Department of Psychiatry and Behavioural Neurosciences
Michael G. DeGroote School of Medicine
Faculty of Health Sciences
McMaster University
Hamilton, Ontario, Canada


Daniel L. Ambrosini, LLB/BCL, MSc, PhD

Legal Counsel and Assistant Professor
Department of Psychiatry and Behavioural Neurosciences
Forensic Psychiatry Program
Michael G. DeGroote School of Medicine
Faculty of Health Sciences
McMaster University
Hamilton, Ontario, Canada


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Author and Disclosure Information

Ana Hategan, MD
Associate Clinical Professor and Geriatric Psychiatrist
Department of Psychiatry and Behavioural Neurosciences
Division of Geriatric Psychiatry
Michael G. DeGroote School of Medicine
Faculty of Health Sciences
McMaster University
Hamilton, Ontario, Canada


James A. Bourgeois, OD, MD
Clinical Professor
Department of Psychiatry
Langley Porter Psychiatric Institute
Consultation-Liaison Service
University of California
San Francisco Medical Center
San Francisco, California

Usha Parthasarathi, MBBS
Associate Clinical Professor and Psychiatrist
Department of Psychiatry and Behavioural Neurosciences
Michael G. DeGroote School of Medicine
Faculty of Health Sciences
McMaster University
Hamilton, Ontario, Canada


Daniel L. Ambrosini, LLB/BCL, MSc, PhD

Legal Counsel and Assistant Professor
Department of Psychiatry and Behavioural Neurosciences
Forensic Psychiatry Program
Michael G. DeGroote School of Medicine
Faculty of Health Sciences
McMaster University
Hamilton, Ontario, Canada


Author and Disclosure Information

Ana Hategan, MD
Associate Clinical Professor and Geriatric Psychiatrist
Department of Psychiatry and Behavioural Neurosciences
Division of Geriatric Psychiatry
Michael G. DeGroote School of Medicine
Faculty of Health Sciences
McMaster University
Hamilton, Ontario, Canada


James A. Bourgeois, OD, MD
Clinical Professor
Department of Psychiatry
Langley Porter Psychiatric Institute
Consultation-Liaison Service
University of California
San Francisco Medical Center
San Francisco, California

Usha Parthasarathi, MBBS
Associate Clinical Professor and Psychiatrist
Department of Psychiatry and Behavioural Neurosciences
Michael G. DeGroote School of Medicine
Faculty of Health Sciences
McMaster University
Hamilton, Ontario, Canada


Daniel L. Ambrosini, LLB/BCL, MSc, PhD

Legal Counsel and Assistant Professor
Department of Psychiatry and Behavioural Neurosciences
Forensic Psychiatry Program
Michael G. DeGroote School of Medicine
Faculty of Health Sciences
McMaster University
Hamilton, Ontario, Canada


Article PDF
Article PDF

Baby Boomers represent a rapidly growing segment of digital device users.1 As these people age, their continued, even increasing, use of the Internet can be expected.1 At the same time, many older adults (age ≥65) are engaged in intimate relationships and regard sexuality as an important part of life.2

At this intersection, the Internet is likely to play a role in geriatric sexuality and “digital intimacy”—in that older adults can adopt patterns of using online dating sites similar to what their younger counterparts engage in. There is a need among clinicians to avoid stereotypical perceptions of “ageism” and the myth of “geriatric asexuality” as a result of older patients’ continued sexual interest and their adoption of social media technologies to facilitate the development of new intimate relationships. Acknowledgement of these realities by clinicians may assist in understanding and communication regarding these important areas of patients’ lives.


Why online dating?

Contemporary social and demographic changes (eg, higher divorce rates, increased longevity, aging of Baby Boomers) have influenced patterns of dating behaviors.3 Consistent with evolutionary theory, studies on courtship behaviors show that women remain the “choosers” of partners in relationships at all ages3; in contemporary society, however, there is an increasing ratio of women to men in later life, and the degree to which this demographic change might influence older men and women who are pursuing sexual relationships is unclear.3 Older adults might be aware of these demographic realities, and may use the Internet to increase their chances of finding a relationship.

For older homosexual men and women, demographic trends also are important because fewer available partners of similar sexual orientation might be available in their immediate communities, similarly incentivizing the use of online dating sites.


Hand in hand: Risk and vulnerability

Clinicians can discuss with geriatric patients who present with questions or concerns about sexuality and risks of online dating. Although risks associated with digital dating can involve anyone, those who are recently divorced, widowed, disabled, or elderly can be targeted by predators or fraudulent schemes, and thus become victims. Recognizing those risks and the vulnerability in the geriatric patient is crucial.

Chronic illness. Age-related physiological changes do not necessarily make one vulnerable; however, chronic diseases of aging, including major neurocognitive disorders, can impair daily function and increase disability and vulnerability. The majority of online dating sites do not discriminate among users, including those with disabilities such as incapacitating neuropsychiatric disorders. The clinician may need to assess cognitive status of patients specific to their capacity to fully understand the risks of use of social media. Inability to accomplish basic mastery of computer skills or inability to maintain appropriate boundaries and safeguards in relationships initiated and maintained using the Internet may assist in this determination. Patients with other problematic Internet use (eg, excessive devotion to online shopping or online gambling) may be prone to misusing social media and dating sites as well. Patients with clear impairment of memory or poor social judgment based on a neurocognitive disorder also might not maintain proper boundaries with social media use.

Feeling alone. Older persons might feel socially isolated, and therefore may be more willing to participate in online dating to increase their chances of establishing an intimate relationship or companionship. Research has shown that increased social ties, participation in groups, contact with friends and family, and perceived social support are associated with longer survival; on the other hand, social disengagement, low participation in leisure activities, and limited social networks are associated with higher risk of major neurocognitive disorders and increased disability.4

Little is known about social vulnerability in institutional settings, but institutional living could decrease social vulnerability in important ways (eg, access to social support, networks and activities, not living alone).4 Although the literature on older adults and “digital” or “virtual” dating is limited, there are essentially no such data from within institutional settings. It is important to separately address the issue of cognitively impaired patients’ capacity to consent to sexual activity both within institutional settings and elsewhere, as it raises numerous ethical dilemmas for clinicians.

Being sexually active. Early research into online dating focused particularly on the risks of sexually transmitted infections (STIs),5 which could be acquired through failure to use condoms with a new partner.6 Older women particularly are less likely to use condoms with new sexual partners.6 Screening at-risk adults should occur regardless of age. Effective interventions are needed to increase condom use in this age group. Research in the general population has started to investigate how the use of technology can minimize the risks associated with online dating.5 The Table5,6 lists strategies that can be used to minimize some of the risks of online dating among geriatric patients, including STIs and victimization.

 

 

Clinicians working with sexually active geriatric patients need to perform sexual risk assessments, complete capacity assessments, and provide preventive measures.


Legal issues

Criminal and civil liability issues have arisen with online dating involving cases of murder, rape, fraud, identity theft, loans, theft, domestic violence, stalking, and burglary. Online dating also raises concerns around the right to fair use of the Internet in different contexts. Flirting in cyberspace can occur with e-mail, text, Twitter, Skype, and Instant Messenger. Practices likely will vary depending on whether older adults are institutionalized or living in the community, as well as their mental status (eg, having a major neurocognitive disorder).

Some questions with legal implications worth considering include:

  • To what extent is there a duty to accommodate healthy sexual relationships in institutionalized settings?
  • At what point does monitoring and supervision become overly intrusive?
  • Are older adults fully aware of the potential ramifications of sharing sensitive information in cyberspace?
  • What is the threshold for capacity to consent among older adults to understand the sexual nature of the act and consent to the act?

Nursing homes and health care providers may become concerned about potential liability if their organization provides digital devices or electronic platforms that are not closely monitored. Clinicians have a duty to protect patients under their care from risks associated with predators who target vulnerable and lonely people, whether financially, emotionally, or physically. Some patients in nursing home settings may benefit from discussing with their family members or attorney the possibility of completing a “sexual power of attorney”7 that could be completed in conjunction with an advance health care directive that addresses or authorizes an agent to make decisions about their sexual activities if cognitively impaired in the future.

One might also consider to what extent local regulatory oversight will protect your patient. Not all jurisdictions regulate online dating services similarly; many existing regulations focus on unfair contracts and pay less heed to safety concerns.

As a result, some dissatisfied clients have been known to sue an online dating service for breach of contract or misrepresentation. One of the most significant issues, however, is making sure there are appropriate background checks. Online dating services may need to change their policies to screen and verify for criminal background checks.8 Older adults interested in online dating should be made aware of these emerging issues.


Disclosures

The authors report no financial relationship with any company whose products are mentioned in this article or with manufacturers of competing products.

Baby Boomers represent a rapidly growing segment of digital device users.1 As these people age, their continued, even increasing, use of the Internet can be expected.1 At the same time, many older adults (age ≥65) are engaged in intimate relationships and regard sexuality as an important part of life.2

At this intersection, the Internet is likely to play a role in geriatric sexuality and “digital intimacy”—in that older adults can adopt patterns of using online dating sites similar to what their younger counterparts engage in. There is a need among clinicians to avoid stereotypical perceptions of “ageism” and the myth of “geriatric asexuality” as a result of older patients’ continued sexual interest and their adoption of social media technologies to facilitate the development of new intimate relationships. Acknowledgement of these realities by clinicians may assist in understanding and communication regarding these important areas of patients’ lives.


Why online dating?

Contemporary social and demographic changes (eg, higher divorce rates, increased longevity, aging of Baby Boomers) have influenced patterns of dating behaviors.3 Consistent with evolutionary theory, studies on courtship behaviors show that women remain the “choosers” of partners in relationships at all ages3; in contemporary society, however, there is an increasing ratio of women to men in later life, and the degree to which this demographic change might influence older men and women who are pursuing sexual relationships is unclear.3 Older adults might be aware of these demographic realities, and may use the Internet to increase their chances of finding a relationship.

For older homosexual men and women, demographic trends also are important because fewer available partners of similar sexual orientation might be available in their immediate communities, similarly incentivizing the use of online dating sites.


Hand in hand: Risk and vulnerability

Clinicians can discuss with geriatric patients who present with questions or concerns about sexuality and risks of online dating. Although risks associated with digital dating can involve anyone, those who are recently divorced, widowed, disabled, or elderly can be targeted by predators or fraudulent schemes, and thus become victims. Recognizing those risks and the vulnerability in the geriatric patient is crucial.

Chronic illness. Age-related physiological changes do not necessarily make one vulnerable; however, chronic diseases of aging, including major neurocognitive disorders, can impair daily function and increase disability and vulnerability. The majority of online dating sites do not discriminate among users, including those with disabilities such as incapacitating neuropsychiatric disorders. The clinician may need to assess cognitive status of patients specific to their capacity to fully understand the risks of use of social media. Inability to accomplish basic mastery of computer skills or inability to maintain appropriate boundaries and safeguards in relationships initiated and maintained using the Internet may assist in this determination. Patients with other problematic Internet use (eg, excessive devotion to online shopping or online gambling) may be prone to misusing social media and dating sites as well. Patients with clear impairment of memory or poor social judgment based on a neurocognitive disorder also might not maintain proper boundaries with social media use.

Feeling alone. Older persons might feel socially isolated, and therefore may be more willing to participate in online dating to increase their chances of establishing an intimate relationship or companionship. Research has shown that increased social ties, participation in groups, contact with friends and family, and perceived social support are associated with longer survival; on the other hand, social disengagement, low participation in leisure activities, and limited social networks are associated with higher risk of major neurocognitive disorders and increased disability.4

Little is known about social vulnerability in institutional settings, but institutional living could decrease social vulnerability in important ways (eg, access to social support, networks and activities, not living alone).4 Although the literature on older adults and “digital” or “virtual” dating is limited, there are essentially no such data from within institutional settings. It is important to separately address the issue of cognitively impaired patients’ capacity to consent to sexual activity both within institutional settings and elsewhere, as it raises numerous ethical dilemmas for clinicians.

Being sexually active. Early research into online dating focused particularly on the risks of sexually transmitted infections (STIs),5 which could be acquired through failure to use condoms with a new partner.6 Older women particularly are less likely to use condoms with new sexual partners.6 Screening at-risk adults should occur regardless of age. Effective interventions are needed to increase condom use in this age group. Research in the general population has started to investigate how the use of technology can minimize the risks associated with online dating.5 The Table5,6 lists strategies that can be used to minimize some of the risks of online dating among geriatric patients, including STIs and victimization.

 

 

Clinicians working with sexually active geriatric patients need to perform sexual risk assessments, complete capacity assessments, and provide preventive measures.


Legal issues

Criminal and civil liability issues have arisen with online dating involving cases of murder, rape, fraud, identity theft, loans, theft, domestic violence, stalking, and burglary. Online dating also raises concerns around the right to fair use of the Internet in different contexts. Flirting in cyberspace can occur with e-mail, text, Twitter, Skype, and Instant Messenger. Practices likely will vary depending on whether older adults are institutionalized or living in the community, as well as their mental status (eg, having a major neurocognitive disorder).

Some questions with legal implications worth considering include:

  • To what extent is there a duty to accommodate healthy sexual relationships in institutionalized settings?
  • At what point does monitoring and supervision become overly intrusive?
  • Are older adults fully aware of the potential ramifications of sharing sensitive information in cyberspace?
  • What is the threshold for capacity to consent among older adults to understand the sexual nature of the act and consent to the act?

Nursing homes and health care providers may become concerned about potential liability if their organization provides digital devices or electronic platforms that are not closely monitored. Clinicians have a duty to protect patients under their care from risks associated with predators who target vulnerable and lonely people, whether financially, emotionally, or physically. Some patients in nursing home settings may benefit from discussing with their family members or attorney the possibility of completing a “sexual power of attorney”7 that could be completed in conjunction with an advance health care directive that addresses or authorizes an agent to make decisions about their sexual activities if cognitively impaired in the future.

One might also consider to what extent local regulatory oversight will protect your patient. Not all jurisdictions regulate online dating services similarly; many existing regulations focus on unfair contracts and pay less heed to safety concerns.

As a result, some dissatisfied clients have been known to sue an online dating service for breach of contract or misrepresentation. One of the most significant issues, however, is making sure there are appropriate background checks. Online dating services may need to change their policies to screen and verify for criminal background checks.8 Older adults interested in online dating should be made aware of these emerging issues.


Disclosures

The authors report no financial relationship with any company whose products are mentioned in this article or with manufacturers of competing products.

References


1. Veenhof B, Timusk P. Online activities of Canadian boomers and seniors. http://www.statcan.gc.ca/pub/11-008-x/2009002/article/10910-eng.htm#tphp. Updated April 23, 2014. Accessed April 26, 2015.
2. Lindau ST, Schumm LP, Laumann EO, et al. A study of sexuality and health among older adults in the United States. N Engl J Med. 2007;357(8):762-774.
3. Alterovitz SS, Mendelsohn GA. Partner p across the life span: online dating by older adults. Psychol Aging. 2009;24(2):513-517.
4. Andrew MK, Mitnitski AB, Rockwood K. Social vulnerability, frailty and mortality in elderly people. PLoS ONE. 2008;3(5):e2232. doi: 10.1371/journal.pone.0002232.
5. Couch D, Liamputtong P, Pitts M. Online daters and the use of technology for surveillance and risk management. International Journal of Emerging Technologies and Society. 2011;9(2):116-134.
6. Bateson DJ, Weisberg E, McCaffery KJ, et al. When online becomes offline: attitudes to safer sex practices in older and younger women using an Australian internet dating service. Sex Health. 2012;9(2):152-159.
7. Hill E. We’ll always have Shady Pines: surrogate decision-making tools for preserving sexual autonomy in elderly nursing home residents. William Mary J Women Law. 2014;20(2):468-490.
8. Doe v Match.com, 789 F Supp 2d 1197, 1199 (CD Cal 2011).

References


1. Veenhof B, Timusk P. Online activities of Canadian boomers and seniors. http://www.statcan.gc.ca/pub/11-008-x/2009002/article/10910-eng.htm#tphp. Updated April 23, 2014. Accessed April 26, 2015.
2. Lindau ST, Schumm LP, Laumann EO, et al. A study of sexuality and health among older adults in the United States. N Engl J Med. 2007;357(8):762-774.
3. Alterovitz SS, Mendelsohn GA. Partner p across the life span: online dating by older adults. Psychol Aging. 2009;24(2):513-517.
4. Andrew MK, Mitnitski AB, Rockwood K. Social vulnerability, frailty and mortality in elderly people. PLoS ONE. 2008;3(5):e2232. doi: 10.1371/journal.pone.0002232.
5. Couch D, Liamputtong P, Pitts M. Online daters and the use of technology for surveillance and risk management. International Journal of Emerging Technologies and Society. 2011;9(2):116-134.
6. Bateson DJ, Weisberg E, McCaffery KJ, et al. When online becomes offline: attitudes to safer sex practices in older and younger women using an Australian internet dating service. Sex Health. 2012;9(2):152-159.
7. Hill E. We’ll always have Shady Pines: surrogate decision-making tools for preserving sexual autonomy in elderly nursing home residents. William Mary J Women Law. 2014;20(2):468-490.
8. Doe v Match.com, 789 F Supp 2d 1197, 1199 (CD Cal 2011).

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Counseling geriatric patients about opportunity and risk when ‘digital dating’
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