Remote Computer Access Wasn’t Local Contact

An investigator who found a 1,718-page document containing patient social security numbers and other information on a computer using a peer-to-peer network did not, through that access, act in the state where the computer was located, the U.S. Court of Appeals for the Eleventh Circuit affirmed Feb. 5 (LabMD Inc. v. Tiversa Inc., 11th Cir., 12-14504, 2/5/13).

The investigator accessed the document while searching P2P networks for computer files that could be used to commit medical or financial identity theft. After locating the document, the investigator called the plaintiff, offering his network security services. The investigator sent ...