United States v. Riggs
United States District Court for the Northern District of Illinois
739 F. Supp. 414 (N.D. Ill. 1990)
Craig Neidorf and Robert Riggs (defendants) conspired to steal a confidential computer text file describing Bell South's E911 emergency-call system, so it could be published in Neidorf's computer newsletter. Riggs unlawfully accessed Bell South's computer system in Georgia, downloaded the file, and transferred it through an interstate network to a bulletin board in Illinois, from which Neidorf accessed and edited it using a computer in Missouri before publishing it. Both were indicted for wire fraud and for transferring stolen goods worth over $5,000 in interstate commerce, and Neidorf moved to dismiss, arguing the electronic file was intangible and couldn't be stolen property.
Whether electronic, confidential proprietary business information constitutes tangible property for the purposes of a crime of theft.