Internet trademark infringement is generally easier to monitor than other types of trademark infringement. This has led to an increasingly large number of Internet infringement claims. Outside of the Internet, a trademark infringement may be more difficult to locate, therefore before the Internet there were much fewer trademark infringement claims. For example, a business owner could often easily steal a trademarked logo or other item and use it in a different location; the original trademark owner could potentially remain unaware of the copyright violation. On the Internet, however, a trademark owner can easily do a complete web search and identify trademark infringements immediately. Federal and state laws place the burden of proof on the original trademark holder with regard to Internet trademark infringement. In order to make a successful trademark infringement case, the trademark holder must prove that use of a trademark is deceptive or causes a clear likelihood of confusion.