Aiding Unauthorized Access to Computer Conviction Upheld

U.S. v. Willis, -- F.3d --, 2007 WL 495313 (10th Cir. 2/16/07) - There was sufficient evidence to support felony conviction for aiding and abetting the unauthorized access of a protected computer because no evidence is necessary of intent to defraud or of the defendant's knowledge of the value of the information obtained. Mr. Willis conceded that, in exchange for meth, he provided access that he had through his employment to a LexisNexis service that supplies personal information. He gets a remand for resentencing because the district court erred in failing to make particularized findings about the scope of the criminal activity he agreed to undertake.