Employee's Access to Employer's Data for Personal, Competitive Gain Was Not 'Unauthorized' Under CFAA

摘要

In LVRC Holdings, LLC v. Brekka [No. 07-17116 (9th Cir. 09/15/2009)], LVRC operated Fountain Ridge, a residential treatment center for addicted persons, in Nevada. As part of its marketing efforts, LVRC retained LOAD, Inc., to provide email, Web site, and related services for the facility. Among other duties, LOAD monitored Internet traffic to LVRC's Web site and compiled statistics about that traffic.