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| REPORT FROM COUNSEL | |
FALL 2004 ISSUENEWS FROM HERTENBURSTEIN.COM
TECHNOLOGY AND THE LAW Lost Database Is Not Insured "If you can't reach out and touch it, it is not insured." That was the gist of a court's ruling in a lawsuit brought by a company that lost a large amount of electronically stored data when an employee inadvertently pressed the "delete" key on a keyboard. The company looked to its insurer to cover the expenses for restoring the data and to recover lost income caused by the disruption. The insurer denied coverage on the basis of policy language that limited coverage to a "direct physical loss of or damage to" covered property. The language from the policy was meant to be interpreted in its ordinary and popular sense. Thus, "physical" means "tangible" or capable of being touched. The information in a computerized database, in and of itself, has no material or tangible existence, unlike a storage medium for information, such as a disk, tape, or even papers in a file cabinet. The court concluded that when the employee sent the data into thin air with an unintended keystroke, there was no direct physical loss within the meaning of the insurance policy. (The court distinguished this case from another case in which the loss of a computer tape and the data on it were covered under a policy covering "physical injury or destruction of tangible property.") Recognizing that the dictionary was not on its side, the company
that lost its data also argued that public policy should weigh
heavily in favor of insurance coverage. After all, loss of
information in the same manner as occurred in this case is common,
and our economy unquestionably is highly dependent on computers and
the intangible information that they contain. However, the court
declined to use public policy as an "interpretive aid." There are
plenty of useful legal principles for construing insurance
contracts, but using public policy to redefine the scope of coverage
agreed to by parties to a contract is not one of them. The lesson:
Questions of insurance coverage are to be answered solely in the
language of the policies and, therefore, careful drafting of policy
language is critical. Joseph was planning to buy a new house from a builder until he came to the conclusion that the builder's sales representative had misled him about the availability of a particular model. In an earlier time, he might have been content to vent to a sympathetic neighbor across his backyard fence, but this is the age of cyberspace. Joseph registered an Internet name that was very similar to that of the builder and then created a website as a forum for relating the reasons for his frustration with the builder. He included a disclaimer making it clear that visitors were not on the builder's website. There was no charge to access the site and the site contained no paid advertisements. Once in a while, an e-mail intended for the builder came to Joseph's site, but he promptly forwarded it to the builder. Also on the website was something Joseph called the "Treasure Chest," a place where readers could exchange information about contractors and tradespeople who had done good work. During the entire time the site was up and running, only one person was mentioned in the Treasure Chest. Although it was nearly empty, the Treasure Chest prompted the builder to sue Joseph under the federal Anti-Cybersquatting Consumer Protection Act (ACPA). The ACPA only applies to someone who, with "a bad-faith intent to
profit," registers or uses a domain name that is identical or
confusingly similar to that owned by someone else. Everyone agreed
that the part of Joseph's website in which he aired his own
complaints against the builder had no profit motive or commercial
aspects, but the builder tried to argue that the Treasure Chest was
a mingling of commercial activities with personal gripes. IRS GETS TOUGH ON ESTATE TAX FRAUD Prosecutions for filing a false Form 706, the federal estate tax return, have been rare. Recently, a federal prosecutor announced a guilty plea by an individual charged with estate tax fraud. The guilty plea may well be a harbinger of a new "get tough" policy by the IRS in an area that up until now has not had a reputation for vigorous criminal enforcement. The defendant in this case was the executor of her mother's estate. She admitted that she intentionally filed a Form 706 that omitted assets worth about $400,000 that should have been included in the estate. The executor could face a term of imprisonment, followed by a term of supervised release, and a large fine. Individuals who stand to be affected by the new emphasis from the IRS on using a carrot and a stick include executors, tax return preparers, and essentially anyone responsible for the completeness and accuracy of an estate tax return. It is important to remember that old income tax returns and other documents that the IRS can obtain in an audit often will allow it to discover assets that have gone unreported. The recently publicized guilty plea by an executor is a not-very-subtle warning by the IRS that estate tax fraud can have consequences beyond dollars and cents.
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