Could electron scatter off vacuum fluctuations?

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asya
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Electron can scatter off virtual photon of Coulomb field (or even emit real photon). But why it cannot do the same off virtual photons of vacuum fluctuations without external field?
 
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Intuitively I understand that.
But formally what is a difference between a virtual photon of Coulomb field and a virtual photon of ground state vacuum fluctuations? Why in the first case conservation lows are OK but in the second one not?