These are examples of retribution, incapacitation, and deterrence. Requiring financial restitution would also be desirable. Rehabilitation is perhaps most challenging. Lilly, et al (2007) note that incarceration has not been positively associated with rehabilitation because it places offenders in the company of other criminals where criminal behavior can be learned. Community service added on to restitution and additional incarceration may be most useful in cases of identity theft but the solution to the problem truly lies in developing systems for preventing potential identity thieves from easily gaining access to personal information and financial data.