In Shamrock Foods Co. v. Gast, (D. Ariz., No. CV-08-0219, 2/20/08), the court held that an employee's act of forwarding his company emails to his personal email account before resigning to work for a competitor was not an "unauthorized" use of the employer's computer for purposes of the Computer Fraud and Abuse Act.  The court held that since the employee was permitted to access the documents in the first place, his use of the computer was "authorized" regardless of his wrongful intent.