Partial Surrogacy occurs when the birth mother contributes the ovum and the sperm is introduced by artificial insemination. She is a biological parent of the child. Commercial Surrogacy means a business-like transaction where a fee is charged for the incubation period. Lastly, there is a Non-Commercial Surrogacy in which there is no formal contract or any payment to the birth mother. It is usually an arrangement between close friends or family members.(1-10) There is no federal policy on the issue of surrogacy, all fifty states have been left to decide theses issues themselves and create their own policies. The majority of the states have not yet legislated on this subject. Those states that have taken positions differ greatly from one another, such as California and Virginia, who have taken opposing viewpoints California is the state that is the most sympathetic to the genetic parents.