America Online, Inc. v. National Health Care Discount, Inc.
United States District Court for the Northern District of Iowa
121 F. Supp. 2d 1255 (2000)
- Written by Eric Cervone, LLM
Facts
America Online, Inc. (AOL) (plaintiff) provided an email service to its users. AOL used filtering programs to block spam emails going through its system. These programs had limited success, however, because spammers easily found ways to thwart them. AOL updated its policies to make it clear that its users were not authorized to use AOL for bulk-email purposes. National Health Care Discount, Inc. (NHCD) (defendant) was an Iowa corporation that sold discount health and dental plans. NHCD contracted with email senders from 10 other states to send marketing emails for NHCD’s plans. These contractors sent unsolicited bulk email messages that traveled through AOL’s servers, which were located in Virginia, to all 50 states. AOL sued NHCD, arguing that NHCD had violated (1) state laws regarding conversion and unjust enrichment and (2) the federal Computer Fraud and Abuse Act (CFAA). AOL moved for partial summary judgment, claiming that Virginia law applied to the state-law claims because the spam emails had harmed AOL’s hardware and finances in Virginia. NHCD argued that Iowa law applied to those claims because it was located in Iowa. The district court considered the summary-judgment motion.
Rule of Law
Issue
Holding and Reasoning (Zoss, J.)
What to do next…
Here's why 899,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 47,000 briefs, keyed to 994 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
