In Royal Truck & Trailer Sales & Service, Inc. v. Mike Kraft and Kelly Matthews (6th Cir., No. 19-1235, 9/09/2020), the court affirmed the district court’s dismissal of the employer Royal’s claims against its former employees for violating the federal Computer Fraud and Abuse Act (“CFAA”) when they took client data with them to a competitor. Kraft and Matthews worked for Royal as salespeople and had authorized access to its computer system. The Royal’s employee handbook prohibited the use of company property for personal or unauthorized purposes. Kraft and Matthews both accessed the employer’s computer system and downloaded customer information before leaving to work for a competitor. The employer sued under CFAA, alleging that Kraft and Matthews exceeded their authorization to access the data. The Sixth Circuit affirmed the district court’s dismissal because both Kraft and Matthews had authorization to access the computer data, and the CFAA regulates access to computer data, not the subsequent misuse of data obtained through authorized computer access.
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