In LVRC Holdings LLC v. Brekka, 581 F.3d 1127, (9th Cir. 2009) the employee emailed to himself competitively sensitive data so he could use it to compete against his current employer. Disagreeing with Citrin, the 9th Circuit refused to hold that an employee’s authorization to access the company computer is based on the law of agency. Instead, the court held that the Computer Fraud and Abuse Act did not apply to the theft because an employee cannot act “without authorization” because his employer gave his “permission to use” the company computer. Id. at 1133. Read relevant article.