International Airport Centers, L.L.C. v. Citrin

This appeal from the dismissal of the plaintiffs suit for failure to state a claim mainly requires us to interpret the word "transmission" in a key provision of the Computer Fraud and Abuse Act, 18 U.S.C. § 1030. The complaint alleges the following facts, which for purposes of deciding the appeal we must take as true. The defendant, Citrin, was employed by the plaintiffs-affiliated companies engaged in the real estate business that well treat as one to simplify the opinion, and call "IAC"-to identify properties that IAC might want to acquire, and to assist in any ensuing acquisition. IAC lent Citrin a laptop to use to record data that he collected in the course of his work in identifying potential acquisition targets.