Creation of Fake Facebook Page Isn’t ‘Unauthorized Access’ Under CFAA, SCA

The creation of a Facebook page to impersonate an individual was not a violation of the Computer Fraud and Abuse Act nor the Stored Communications Act because such conduct did not amount to access “without authorization” or “exceeding authorized access” as envisioned under the statutes, the U.S. District Court for the Northern District of Illinois held June 1 (Bittman v. Fox, N.D. Ill., 1:14-cv-08191, 6/1/15).

Judge James F. Holderman said the plaintiff did not allege that the creators of the page accessed her personal computer or Facebook account without authorization, but instead that they simply violated the ...