Tourists can also go sea kayaking or power kiting and fishing. C-kites are the oldest style of LEI used for traction kiting. This behaviour is known as ballooning or kiting. The spine is open for walking, jogging, cycling, kiting and other similar activities. Barry Hill Palmer made several Rogallo-winged hang gliders for free-flight kiting. This strategy, known as "chaining", is a form of check kiting. Any modifier that decreases an opponent's speed will allow more efficient kiting. Snow kiting has also become popular. Snow kiting has also become popular in recent years. Crimes committed by victims include credit-card fraud, check kiting, and embezzlement. Lowery was tainted by the House check kiting scandal and lost the primary to Cunningham. Taking advantage of the float period (cheque kiting) to delay the notice of non-existent funds. Hutton's most serious trouble came from a check kiting scandal that was uncovered in 1985. Check kiting is illegal in many countries. The aerostats are usually, but not always, shaped to achieve a kiting lifting effect.