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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)


Facts

America Online, Inc. (AOL) (plaintiff) provided an email service to its users. AOL used various filtering programs to try to block spam emails going through its system. These programs had limited success, however, because spammers easily found ways to thwart AOL’s programs. AOL updated its policies to make it clear that its users were not authorized to use AOL for bulk-email purposes. Several people sent a large amount of spam email through AOL’s service advertising discount optical and dental plans from National Health Care Discount, Inc. (NHCD) (defendant). AOL sued NHCD, arguing that NHCD had violated the Computer Fraud and Abuse Act (CFAA).

Rule of Law

Issue

Holding and Reasoning (Zoss, J.)

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