• In a recent decision, the U.S. Court of Appeals for the Ninth Circuit ruled that employees may be held liable under the Computer Fraud and Abuse Act, 18 U.S.C. 1030 et seq., when they steal or remove electronic files or data in violation of their employers’ written computer-use policies. The Court held that an employee “exceeds authorized access” to data on an employer’s computer system by taking actions that are prohibited by written policies establishing acceptable use, such as prohibitions against copying or e-mailing files to competitors. U.S. v. Nosal, No. 10-10038 (9th Cir. Apr. 28, 2011).