A.V. v. iParadigms
In A.V. v. iParadigms, LLC, 562 F.3d 630 (4th Cir. Apr. 16, 2009), the Fourth Circuit interpreted the Computer Fraud and Abuse Act (CFAA), 18 U.S.C.S. § 1030(a)(5)(A)(iii) & (B)(i), to allow a company to collect damages from a minor based on the man-hours spent by the company investigating ostensibly unauthorized access to its computer by the minor. The court held that this could satisfy the $5,000 minimum threshold for "economic" damages established by the CFAA. The Court was unanimous in its ruling, remanding the case back to the trial court and overturning the lower court's prior decision that had dismissed this counterclaim by iParadigms.
The Court also interpreted fair use doctrine broadly in holding in favor iParadigms, a company that combats plagiarism by students who copy their homework off the internet. "iParadigms' use of these works was completely unrelated to expressive content and was instead aimed at detecting and discouraging plagiarism," and hence qualified as fair use. Accordingly, the Court granted summary judgment in favor of iParadigms and against the plaintiffs' claims.