Abstract: Credit cards are an integral part of the American economy. 1 Due to the widespread use of credit cards and checks, we have become a "cashless society." 2 Credit card usage has grown rapidly, 3 therefore, "[t]he plastic credit card seems destined to replace the paper check as the primary means of paying for goods and services.' 4 The extensive use of credit cards, however, has its drawbacks.Credit card fraud is foremost among these problems. 5 The to-1 For an early observation of the role of credit cards in the American economy, see Note, The Apportionment of Credit Card Fraud Loss, 4 U.C.D. L. REV.377, 377 (1971). 2 In 1972, an Illinois Commission on credit card fraud observed that we were "quickly becoming a cashless society."ILL.LEG.INVESTIGATING COMM'N, CREDIT CARD FRAUD IN ILLINOIS (1972).Two years later, Justice White declared that the country had entered the "era of the 'cashless' society."United States v.