v. Citrin, the Seventh Circuit Court of Appeals evaluated the dismissal of the plaintiffs' lawsuit for failure to state a claim based upon the interpretation of the word "transmission" in the Computer Fraud and Abuse Act, 18 U.S.C. § 1030.
[3] IAC employed the defendant, Jacob Citrin, to identify potential acquisitions and record data about these properties.
[3] He deleted the data on the laptop before returning it to IAC, using a secure-erasure software that rendered files irrecoverable.
The district court agreed and dismissed the lawsuit since it determined that the deletion of the files did not violate the CFAA.
"Damage" here included "any impairment to the integrity or availability of data, a program, a system, or information.