Another CFAA Case Dismissed Because Plaintiff Only Recited Elements in Complaint

In North American Ins. Agency, Inc. v. Bates, the United States District Court for the Western District of Oklahoma dismissed the plaintiff’s Computer Fraud and Abuse Act claim because, rather than alleging facts to support the claim, the plaintiff merely recited the elements in the Complaint: “A pleading that offers labels and conclusions or a formulaic recitation of the elements of a cause of action will not do. Nor does a complaint suffice if it tenders naked assertion[s] devoid of further factual enhancement.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotations and citations omitted).