Givaudan Fragrances Corp. v. Krivda, 2013 WL 5411475 (D.N.J. Sept. 26, 2013)
Generally, “an employee who may access a computer by the terms of his employment is authorized to use that computer for purposes of CFAA evenif his purpose in doing so is to misuse or misappropriate the employer’s information.”
Here, Krivda was authorized to access that information…. Relying upon the cases above, the term “exceeds authorized access,” refers to one who had access to part of a system and then accessed other parts of the computer system to which he had no permissible access. Here Krivda had permissible access to the formula management database system. Givaudan’s proposition that Krivda could not “review and print” does not fall within the definition of exceeds authorized access.
