Orin S. Kerr Associate Professor George Washington University Law School
[EMAIL PROTECTED] (202) 994-4775

INSTALLING A KEYLOGGER ON A PERSONAL COMPUTER DOES NOT VIOLATE THE WIRETAP
ACT, DISTRICT COURT HOLDS

On October 8, a district court judge in Los Angeles dismissed a wiretapping
indictment involving the use of a keylogging device installed on a personal
computer. The judge held that Congress had not prohibited the use of a key
logger on a personal computer because a personal computer was not a computer
system affecting interstate commerce. My sense is that the court's approach
is wrong. The government has filed a motion for reconsideration, but that
motion has not yet been decided. The case is United States v. Ropp, Cr. 04-
3000-GAF (C.D. Cal., Oct 8, 2004) (Feess, D.J.) (unpublished, or at least
not yet on Westlaw).

In this case, Larry Lee Ropp installed a device known as a "KeyKatcher" on
the desktop computer of Susan Beck, who worked at an insurance company in
Orange County, California. The KeyKatcher is a keylogging wiretapping device
that intercepts all keystrokes passing by the point of interception. Ropp
installed the device on the cable that connected Beck's keyboard to her
computer's CPU, and the device picked up Beck's e-mails and other messages
sent via her computer.

The government indicted Ropp for violating the wiretapping statute, 18
U.S.C. 2511, on the ground that he had intercepted Beck's electronic
communications. Specifically, the e-mails and other communications that Beck
had sent had originated at her keyboard and then travelled from her computer
across the net. According to the government's theory, these communications
were the "electronic communications" Ropp intercepted.

In a meandering opinion, Judge Feess rejected this approach and granted a
motion to dismiss the indictment. The e-mails and other communications were
not "electronic communications," Judge Feess held, and therefore the Wiretap
Act had not been violated. According to 18 U.S.C. 2510(12), an electronic
communication must be "transmitted in whole or in part by a . . . system
that affects interstate or foreign commerce," Judge Fees noted. Judge Fees
viewed this as requiring that the interception occur at the location of a
"system that affects interstate or foreign commerce," and then had to decide
whether the "system" here was only Beck's PC, or rather Beck's PC together
with the network to which it was connected. The court held that the relevant
"system" was Beck's PC, and that this personal computer, standing alone, was
not a system that affected interstate commerce. Thus the court dismissed the
indictment. (The opinion also had discussions of United States v. Scarfo and
the now-withdrawn panel opinion in United States v. Councilman, but in the
end did not seem to rely on them.)

Judge Feess's opinion seems wrong to me. First, consider the text. The text
of the statute does not require that the intercept occur on a system that
affects interstate commerce. Rather, the text requires only that
communications collected be a "transfer of signs [and] signals" that are
"transmitted in whole or in part" over a system that affects interstate
commerce. Surely that was the case here: Beck's signals originated at her
keyboard, and were then sent across the Internet. While they may or may not
have been intercepted on a system that affected interstate commerce --
depending on the somewhat metaphysical question of how you define a computer
"system" in a network context (more on that below) -- the statute does not
actually require that.

Second, the implications of this opinion would seem to take lots and lots of
conduct that Congress thought it was prohibiting outside of the Wiretap Act.
For example, the definition of "electronic communications" used for e-mail
and computers is relatively similar, at least in relevant part, to the
definition of "wire communication" used for telephones. No court has ever
held that the police could install a bugging device on a phone without
violating the Wiretap Act simply by installing the device on the cord
connecting the phone's handset to the base. Courts have traditionally looked
at the origin point of the signal, not whether the device was installed on a
machine that itself seemed to affect interstate commerce. What matters is
that the device picks up the communications in the course of transmission,
not whether the communications were collected at the phone or the switching
station.

Finally, Judge Feess's conclusion that a personal computer connected to the
Net is not part of a system in a interstate commerce seems to cut across the
grain of existing case law. A number of courts have suggested that any
communication connected to the Internet is tantamount to being in interstate
commerce. See, e.g., United States v. Carroll, 105 F.3d 750 (1st Cir. 1997).
Judge Feess argued that Beck could have written her e-mails and the like on
a stand-alone computer, and if that had happened, her communications would
not be on a system affecting interstate commerce. But as I see it, that's
just arguing by analogy by changing the relevant facts. The fact remains
that Beck's computer was connected to the Internet, and that the device
picked up communications in the course of transmission from the keyboard to
their recipients.

Orin S. Kerr Associate Professor George Washington University Law School
[EMAIL PROTECTED] (202) 994-4775




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