The Intended Use Theory of access under the Computer Fraud and Abuse Act (“CFAA”) has been all the rage since the Ninth Circuit handed down its opinion in United States v. Nosal but that doesn’t mean the Agency Theory has gone by the wayside. Just last week a district court used the Agency Theory (set forth by the Seventh Circuit in International Airport Centers, LLC v. Citrin) to determine that an employee, who after changing loyalties from his existing employer to another, accessed his then-employer’s computer and deleted data from the computer before turning it back in, destroyed data without authorization in violation of the Computer Fraud and Abuse Act.
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