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)
Shurgard Storage Centers (plaintiff) alleged that competitor Safeguard Self Storage (defendant) recruited several of Shurgard's employees to obtain trade secrets, and that those employees, while still nominally employed by Shurgard, used Shurgard's own computers to send proprietary information to Safeguard; Shurgard sued under the Computer Fraud and Abuse Act (CFAA), and Safeguard moved to dismiss, arguing the employees always had authorized computer access and that Shurgard hadn't shown the CFAA's required damage element.
Whether, if someone has authority to access a computer for some purposes but accesses that computer for an unauthorized purpose, that is considered unauthorized access that can give rise to liability under the Computer Fraud and Abuse Act.