The U.S. District Court for the District of Massachusetts held, in Pine Environmental Services, LLC, v. Charlene Carson, et al., that a company laptop whose hard drive had been wiped clean by a former employee was not a “protected computer” within the meaning of the Computer Fraud and Abuse Act (CFAA) because it was not being used in interstate commerce at the time the ex-worker wiped the drive.  Depending on how it is interpreted by other courts, the court’s reasoning could greatly restrict the utility of the CFAA to employers (and prosecutors) who want to go after rogue employees or hackers who harm company computers or make off with valuable information.