The plaintiff was granted a temporary restraining order and, after a contested hearing, was awarded a final restraining order (FRO). At issue was whether the plaintiff could establish a “dating relationship” as a necessary element in receiving the FRO. The parties met at a gym, where the plaintiff worked and the defendant regularly exercised. They never went on a date, never held hands, never kissed, and never met one another’s friends. But they did exchange more than 1300 — often sexually explicit — text messages. The Appellate Division agreed with the trial court that these electronic communications amounted to a dating relationship.
