Why is the tort of intentional infliction of emotional distress typically unsuccessful in consumer privacy cases?

The tort of intentional infliction of emotional distress (IIED)occurs when one acts abominably or outrageously with intent to cause another to suffer severe emotional distress, such as issuing the threat of future harm. there are four elements laid out in the Second Restatement of Torts for intentional infliction of emotional distress: "(1) the conduct must be extreme and outrageous; (2) the conduct must be intentional or reckless; (3) it must cause emotional distress; and (4) the distress must be severe [3]. It is difficult it is to prove a case intentional infliction of emotional distress.