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International Airport Centers v. Citrin

440 F.3d 418 (2006)

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International Airport Centers v. Citrin

United States Court of Appeals for the Seventh Circuit

440 F.3d 418 (2006)

Facts

Jacob Citrin (defendant) was employed by International Airport Centers, LLC (IAC) (plaintiff) to find properties that IAC might want to buy. As part of his work, Citrin used a laptop owned by IAC to record the data he collected. Citrin decided to breach his employment contract and go into business for himself. However, before Citrin turned in his IAC laptop, he loaded a program onto the laptop that securely erased files containing (1) evidence that Citrin had engaged in misconduct while employed by IAC and (2) data that Citrin had gathered for IAC. IAC sued Citrin, alleging that Citrin’s destruction of the laptop files violated the federal Computer Fraud and Abuse Act (CFAA). The district court found that IAC’s allegations, even if true, did not state a claim for a violation of the CFAA and dismissed the claim. IAC appealed the dismissal to the Seventh Circuit.

Rule of Law

Issue

Holding and Reasoning (Posner, J.)

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