The U.S. District Court for the Middle District of Florida has held, in Vista Marketing, LLC v. Terri A. Burkett and Joseph R. Park, that civil liability under the Stored Communications Act (SCA) does not extend to co-conspirators. Although there are federal statutes extending criminal liability to co-conspirators and aiders and abettors of those who violate criminal laws, which would apply to the SCA like other criminal statutes, the court here held that there is no “secondary” civil liability under the SCA because that statute itself does not address liability for co-conspirators or aiders and abettors.