Snow v. DirecTV, Inc.

Snow v. DirecTV, Inc.450 F.3d 1314In the USA Court docket of Appeals for the Eleventh CircuitCase Quantity 05-13687Before Circuit Decide Carnes, Circuit Decide Wilson, and Circuit Decide PryorDecided on June 01, 2006

Relevancy of the case: Does the Storage Communications Act protect a publicly obtainable web site?

Statutes and Provisions Concerned

The Saved Communications Act, 18 U.S.C. § 2701 et seq. (“SCA”)
The Federal Guidelines of Civil Process (Rule 12(b)(6))

Related Info of the Case

The appellant, Snow, created a non-public assist group web site with an digital bulletin board.
He restricted the members related to the respondent, DirecTV, and regulation corporations Yarmuth and Stump from registering on his web site.
Staff of DirecTV and the abovementioned regulation corporations accessed the web site’s digital bulletin board with out authorisation, which allegedly violated the provisions of the SCA.
The district courtroom dismissed Snow’s criticism, ruling that the digital bulletin board was not an “digital storage”. Therefore, it will likely be out of the scope of safety below the SCA.

Outstanding Arguments by the Counsels

The appellant’s counsel argued that:

Staff of DirecTV, Stump, and Yarmuth accessed the digital bulletin board on Snow’s web site with out authorisation, breaching their circumstances below the SCA.
The digital bulletin board must be thought-about “digital storage” below the SCA, thus making unauthorised entry unlawful.

The respondent’s counsel submitted that:

The messages on Snow’s digital bulletin board don’t meet the SCA’s “digital storage” definition.
Snow’s web site was configured to permit public entry, which doesn’t meet the SCA’s safety necessities.

Opinion of the Bench

Snow’s web site wasn’t configured to limit public entry, i.e., it was simply obtainable for public use. This availability will fail the necessities to make the defendants’ actions unlawful below the SCA.

Closing Resolution

The courtroom dominated in opposition to Snow and dismissed his claims by rejecting the attraction.