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Shurgard Storage Centers, Inc. v. Safeguard Self Storage, Inc.

United States District Court for the Western District of Washington
119 F. Supp. 2d 1121 (2000)


Facts

Shurgard Storage Centers, Inc. (Shurgard) (plaintiff) and Safeguard Self Storage, Inc. (Safeguard) (defendant) were competitors in the self-storage industry. Shurgard claimed that Safeguard was recruiting key Shurgard employees in order to obtain Shurgard’s trade secrets. Shurgard also claimed that some of those employees, while still employed by Shurgard, were using Shurgard’s computers to send trade secrets to Safeguard. Shurgard sued Safeguard under the Computer Fraud and Abuse Act (CFAA), among other federal laws. Safeguard argued that there was no claim under the CFAA because Shurgard had not alleged that the employees had accessed the trade secrets without authorization. Shurgard countered that the employees’ authorization ended when they began acting as agents for Safeguard. Safeguard also argued that Shurgard did not present evidence showing that the alleged behavior caused damage as required by the CFAA.

Rule of Law

Issue

Holding and Reasoning (Zilly, J.)

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