In the example of Harassing Telephone Calls, what was Zach's primary action that constituted harassment?

Zach's primary action that constituted harassment was leaving several voicemails that included threats. In the context of harassment, the frequency and nature of the communication play a critical role. Voicemails that contain threats are particularly serious as they not only demonstrate a pattern of unwanted contact but also introduce an intimidating and aggressive element that exceeds normal inquiries or casual communication.

Harassment laws typically require multiple contacts or communications that create a persistent and unwanted presence in the victim’s life. In this case, the threats in the voicemails indicate a clear intention to instill fear or emotional distress, which qualifies his behavior as harassment.

Other actions listed, such as calling to inquire about Penny's new relationship or making a single phone call, do not typically meet the legal threshold for harassment on their own, as they may not involve the same level of intimidation or unwanted persistence. Sending a text message could also be benign depending on its content, further supporting that the voicemails with threats were the definitive action that constituted harassment.