The National Attorneys General Training & Research Institute

The National Attorneys General Training & Research Institute The National Attorneys General Training & Research Institute

Cybercrime Newsletter Jan - Feb 2016

The following is a compendium of news reports, case law and legislative actions over the latest bi-monthly period that may be of interest to our AG offices that are dealing with cyber-related issues. Neither the National Association of Attorneys General nor the National Attorneys General Training & Research Institute expresses a view as to the accuracy of news accounts, nor as to the position expounded by the authors of the hyperlinked articles.

Cyberspace Law Briefs

NY Bar: Jurors Need Instructions on Social Media Use

Social media have become such an integral part of life that jurors need to have explicit instructions on its use, according to a report by the New York Bar Association. The report finds that jurors should be given detailed explanations of the legal and practical reasons why they must not use social media to talk about or research a trial, as well as examples of how using social media can lead to a mistrial. The report may be accessed at

And see…

NYC Bar Weighs in on Linkedin Profiles and Lawyer Advertising

A lawyer’s Linkedin profile constitutes attorney advertising only if it meets a series of criteria, according to Formal Opinion 2015-7 of the New York City Bar Association’s Committee on Professional Ethics. The opinion states that resume elements, such as lists of legal skills and third-party endorsements, do not constitute advertising and are not subject to legal advertising rules unless they are posted specifically for the purpose of attracting clients. The opinion may be accessed at

Study: Can Robots Be Lawyers?

Attorney employment would drop slightly more than 13 percent if automation were applied to a law practice, according to the study “Can Robots Be Lawyers?” conducted by University of North Carolina law professor Dana Remus and MIT labor economist Frank Levy. The researchers categorized tasks based on the percentage of lawyer hours that could be reduced by automation. The study report can be accessed at

Nebraskans Can Charge Electric Cars Near the Capitol

The Nebraska Community Energy Alliance installed a public charging station at its office at the Ferguson House, a historic mansion across the street from the state Capitol. According to the Alliance, it takes up to four hours to charge a typical electric car at a charging station. The cost of the Alliance’s vehicle charge is $1.

Governor: Wi-Fi in NYC Subways by Year End

New York Governor Andrew Cuomo announced that the State will add $8 billion toward the Metropolitan Transportation Authority’s (MTA’s) $26.1 billion budget to redo at least 30 stations, install cameras on city buses and make Wi-Fi available at all 278 MTA stations by year end. Only 140 stations currently have Wi-Fi access.

In the State Courts

Suppression of Text Messages

People v. Herrara, 357 P. 3d 1227 (Colo. Oct. 26, 2015).

The Supreme Court of Colorado affirmed the trial court’s order in a case where Matthew Herrara was charged with sexual assault of a child, Internet exploitation of a child and Internet luring of a child, deciding that the trial court properly suppressed text messages found on Herrara’s phone because they did not fall within the scope of the warrant or within the plain view exception to the warrant requirement. The court further found that the warrant permitting the police to search Herrara’s cell phone for indicia of ownership did not permit the police to search every folder in the phone because if it did, it would qualify as a general warrant in violation of the Fourth Amendment particularity requirement.

State v. Lowell, 275 Ore. App. 365 (Dec. 9, 2015).

The Oregon Court of Appeals reversed the lower court’s judgment, finding that the text messages on Vincent Lowell’s cell phone should have been suppressed because the search incident to arrest exception under the Fourth Amendment categorically does not apply to digital data stored on cell phones.

But see…

Glispie v State, 2015 Ga. App. LEXIS 748 (Nov. 20, 2015).

The Court of Appeals of Georgia affirmed, finding the trial court did not err in denying Jaylend Glispie’s motion in limine to exclude text messages taken from a cell phone found on him at the time of the arrest. The court found there was a fair probability that the phone contained evidence of drug sales, given that Glispie possessed a large number of suspected drugs, cash, a residue-laden razor and two cell phones at the time of his arrest. The court further found the State presented sufficient evidence to support a finding that the text messages were to and from Glispie. The court reversed other issues on appeal.

Search of Cell Phone Contents

Johnson v. State, 2015 Ark. 387 (Oct. 29, 2015).

The Supreme Court of Arkansas affirmed the circuit court’s judgment, finding that the lower court did not err in denying James Johnson’s motion to suppress a search warrant that resulted in the search of the contents of his cell phone. The court found that 1) a detective’s affidavit established that Johnson was one of two suspects in a shooting incident; 2) the phone was found on Johnson at the time of his arrest; and 3) Johnson and another individual were implicated in the shootings. The court therefore found it was reasonable to infer that the cell phone was used to communicate with others regarding the shootings.

Ed. Note: Assistant Attorney General Ashley Younger of the Arkansas Attorney General’s Office represented the State.

And see…

State v. Davis, 2015 Ida. App. LEXIS 114 (Nov. 4, 2015)

The Court of Appeals of Idaho reversed the trial court’s order and remanded the case, finding that while the trial court properly determined that the affidavit provided for a search warrant contained evidence from an independent source, it erred in granting Jacob Davis’ motion to suppress the contents of his cell phone. The court found the evidence was sufficient to establish probable cause for the warrant, making the search and seizure of Davis’ cell phone lawful where the minor victims indicated, prior to the discovery of Davis’ cell phone by the police during a traffic stop, that child pornography was on his cell phone.

Ed. Note: Deputy Attorney General Kenneth Jorgensen of the Idaho Attorney General’s Office represented the State.

People v. Butler, 2015 IL App (1st) 131870 (Dec. 24, 2015). An Illinois appellate court reversed a lower court’s judgment, determining that an officer’s actions in conducting a warrantless search of Robert Butler’s cell phone in order to contact his family did not fall under the community caretaking exception to the Fourth Amendment because the officer had less intrusive means at his disposal for accomplishing the same task. The court further found there was no immediate and clear danger to the police or others, and there was no reason why the officer could not have waited and secured a warrant prior to searching Butler’s cell phone.

Commonwealth v. Dorelas, 2016 Mass. LEXIS 9 (Jan. 14, 2016). The Massachusetts Supreme Judicial Court affirmed the lower court judgment, finding that where there was probable cause that evidence of communications linking Denis Dorelas to the crimes under investigation would be found in the files on the cell phone, and those communications could have been stored in photographic form, a search of the photographic files was reasonable. The court determined the photographs were properly seized as evidence linking Dorelas to the crimes.

Admissibility of Reattached GPS Tracker Evidence

Turner v. Commonwealth, 777 S.E. 2d 569 (Va. App. Oct. 27, 2015).

The Court of Appeals of Virginia affirmed a lower court judgment, determining that evidence from a reattached GPS tracker was admissible because its reattachment was part of a continuing search pursuant to a warrant. The court found no new warrant was required, and the warrant’s good cause extension was not unconstitutional as probable cause supported the original warrant. The court further found that photographs of Brian Turner’s mail were admissible because the best evidence rule and the completeness rule did not apply as they were not offered to prove the mail’s contents.

Ed. Note: Assistant Attorney General Benjamin Katz of the Virginia Attorney General’s Office represented the Commonwealth.

Monitoring of GPS Signals

Thornton v. Commonwealth, 2015 Ky. LEXIS 1942 (Oct. 29, 2015).

The Supreme Court of Kentucky affirmed the lower court judgment, ruling the police monitoring of GPS signals from the vehicle as Robert Thornton drove it in areas where visual surveillance from public places would have sufficed to reveal his location did not invade any legitimate expectation of privacy and thus, the trial court did not err in denying his motion to suppress. The court further found that the trial court did not err in denying Thornton’s motion for a directed verdict on two robbery counts, as the jury also had the benefit of the surveillance videos.

Ed. Note: Assistant Attorney General Bryan Morrow of the Kentucky Attorney General’s Office represented the Commonwealth.

Particularity Requirement of Warrant

State v. Besola, 2015 Wash. LEXIS 1315 (Nov. 5, 2015).

In this case where Mark Besola was prosecuted for possession of and dealing in child pornography, the Supreme Court of Washington reversed and remanded the case, finding that the search warrant failed to meet the particularity requirement. The court found the warrant provided for the seizure of items that were legal to possess under the First Amendment, and a citation to the child pornography statute at the top of the warrant did not modify or limit the items listed in the warrant.

Exclusionary Rule

Rivera v. Commonwealth, 778 S.E. 2d 144 (Va. App. Nov. 10, 2015)

The Court of Appeals of Virginia affirmed the lower court’s judgment, finding that although it was months after the U.S. Supreme Court determined that the warrantless search of a cell phone violated the Fourth Amendment, the exclusionary rule did not warrant the suppression of the evidence collected from the warrantless search of the cell phone because the police detective acted with an objectively reasonable good faith belief that his conduct was lawful under then existing precedent. The court found that therefore applying the exclusionary rule to exclude the evidence obtained from the search of Geoffrey Rivera’s cell phone under the circumstances would not have substantially deterred future police misconduct.

Ed. Note: Assistant Attorney General Benjamin Katz of the Virginia Attorney General’s Office represented the Commonwealth.

Plain View Exception

State v. Cardwell, 2015 S.C. App. LEXIS 206 (Sept. 2, 2015).

The Court of Appeals of South Carolina affirmed the circuit court’s judgment, finding Sarah Cardwell’s convictions for unlawful conduct toward a child and first degree sexual exploitation of a minor were proper. The court ruled the circuit court did not err in denying Cardwell’s motion to suppress the video file seized from her laptop since she had no reasonable expectation of privacy in the minor’s photograph. The court further found the photograph was in the chief’s plain view and gave the appearance that the video file’s content included a minor engaging in inappropriate sexual behavior, so therefore the circuit court properly denied the motion to suppress the video file pursuant to the plain view exception to the warrant requirement. The court also found the inevitable discovery doctrine further supported the denial of the motion to suppress.

Ed. Note: Assistant Attorney General William Birch of the South Carolina Attorney General’s Office represented the State.

And see…

People v. Swietlicki, 2015 CO 67 (Nov. 23, 2015).

The Supreme Court of Colorado reversed the lower court’s judgment, determining the warrantless seizure of Paul Swietlicki’s laptop was justified under the plain view exception to the warrant requirement. The court found the Wisconsin officer observed the laptop in plain view from a lawful vantage point, had probable cause to believe the laptop was associated with child pornography and had a lawful right of access to the laptop.

Admissibility of Photograph

Commonwealth v. Loughnane, 2015 Pa. Super. LEXIS 766 (Nov. 23, 2015).

A Pennsylvania Superior Court affirmed in part, although finding the best evidence rule did not apply to a still photograph of Daniel Loughnane’s truck taken from a security videotape that was erased and taped over by a camera security system, as per the security company’s routine practice, before the police requested a copy. The court did find that an employee of the security company was able to authenticate the photograph.

Proof of Venue

Nickolls v. State, 2015 Miss. LEXIS 586 (Dec. 10, 2015).

The Mississippi Supreme Court reversed Samuel Nickolls’ convictions on 10 counts of video-voyeurism because venue was proved, as the parties’ stipulation of facts, which was the sole trial evidence, was silent on where Nickolls’ transfers of prohibited filming within the statute of limitation occurred. The court noted that Nickolls’ residence in a certain county could not prove venue, and Nickolls did not admit the stipulation provided sufficient evidence to convict him.

Ed. Note: Alicia Ainsworth, Special Assistant Attorney General in the Mississippi Attorney General’s Office, represented the State.

Obtaining Historical Cell Site Location Information

Ford v. State, 2015 Tex. Crim. App. LEXIS 1412 (Dec. 16, 2015).

A Texas criminal appeals court affirmed the lower court judgment, ruling that the State’s warrantless acquisition of four days’ worth of historical cell site location information recorded by Jon Ford’s cell phone service provider did not violate the Fourth Amendment because the provider, as a third party, gathered and maintained the information as business records of the service provided to Ford’s phone, and Ford did not have a legitimate expectation of privacy in the data. The court found that therefore the State did not violate Ford’s rights when it obtained that information by way of a court order.

Expectation of Privacy in Cloud-Based Cell Provider Data

Commonwealth v. Jordan, 2015 Mass. Super. LEXIS 141 (Dec. 30, 2015).

A Massachusetts superior court ruled that Michael Jordan’s motion to suppress information from his cell phone provider as to his use of the phone over a six-week period was allowed as to cell site location information, text messages and contact information because Jordan had a reasonable expectation of privacy therein even though it was stored in the Cloud by the service provider, rather than saved only on Jordan’s phone. However, the court ruled that Jordan’s motion to suppress was not warranted with respect to information identifying the person who subscribed to the cell phone service or as to call details, as Jordan had no reasonable expectation of privacy therein.

Warrantless Electronics Search as Probation Condition

In re Mark C., 2016 Cal. App. LEXIS 65 (Jan. 28, 2016).

A California Court of Appeal modified a juvenile defendant’s probation conditions, ruling that a probation condition requiring the juvenile to submit to warrantless searches of his electronics, including passwords, was invalid because there was no relationship between the condition and his underlying offense of possessing a prohibited knife on school grounds.

Ed. Note: The People were represented by Deputy Attorneys General Eric Share and Laurence Sullivan of the California Department of Justice.

In the Federal Courts

Exclusionary Rule

U.S. v. Dreyer, 804 F.3d 1266 (9th Cir. Nov. 4, 2015)

The Ninth Circuit Court of Appeals affirmed the U.S. District Court for the Western District of Washington’s denial of the motion to suppress and remanded the case, ruling that application of the exclusionary rule to suppress child pornography evidence found on Michael Dreyer’s computer was not warranted. The court found it was not shown that suppression was necessary to prevent future violations.

Attachment and Monitoring of GPS Device

U.S. v. Martin, 2015 U.S. App. LEXIS 19616 (7th Cir. Nov. 10, 2015).

The Seventh Circuit Court of Appeals affirmed the judgment of the U.S. District Court for the Central District of Illinois, determining that a “reasonably well-trained officer” would have known that U.S. v. Garcia permitted him or her to attach a GPS device to a suspect’s vehicle and monitor it without having to seek a warrant. The court noted that it was irrelevant whether the officers had any training on Garcia’s holding or if they consulted legal counsel or prosecutors regarding the legality of their GPS installation and subsequent tracking.

Delay in Obtaining Search Warrant

U.S. v. Johnson, 806 F.3d 1323 (11th Cir. Dec. 1, 2015).

The Eleventh Circuit Court of Appeals affirmed the judgment of the U.S. District Court for the Middle District of Florida, finding that because Alan Johnson and Jennifer Sparks abandoned their cell phone within three days of having lost it, they lacked standing to challenge law enforcement’s 23-day delay between recovering the phone and obtaining a search warrant to search it for child pornography. As to one video on the phone, the court also found that an officer exceeded the scope of the prior private search before receiving a warrant, but that error had no effect on the trial court’s determination of probable cause supporting the issuance of two search warrants.

Particularity Requirement for Search Warrants

U.S. v. Horton, 2016 U.S. App. LEXIS 1106 (3rd Cir. Jan. 22, 2016).

The Third Circuit Court of Appeals ruled the particularity requirement was satisfied, affirming the judgment of the U.S. District Court for the Eastern District of Pennsylvania. The court found that contrary to Fitzgerald Horton’s argument, the search warrant, which defined computer hardware broadly, covered his cell phone, so Horton did not and could not argue that his cell phone was not computer hardware as defined in the warrant.

Federal Rule of Evidence 801(d)(1) Applicability to Affidavit

U.S. v. Welch, 2016 U.S. App. LEXIS 976 (8th Cir. Jan. 21, 2016).

The Eighth Circuit Court of Appeals affirmed Joshua Welch’s conviction in the U.S. District Court for the District of Nebraska, ruling Fed. R. Evid. 801(d)(1) did not apply to an affidavit containing an investigating agent’s statements about the types of evidence that officers would expect to find in the home of a typical consumer of child pornography. The court ruled that therefore it was unnecessary to determine whether the affidavit was otherwise admissible because its exclusion did not prejudice the outcome of the trial.

Privacy Interests in Video Recordings

U.S. v. Thompson, 2016 U.S. App. LEXIS 1688 (7th Cir. Feb. 1, 2016).

The Seventh Circuit Court of Appeals ruled that where an informant, who was equipped with hidden audio video-recording devices, bought drugs from Aaron Thompson at an apartment, suppression of the recordings was not warranted under the Fourth Amendment, thereby affirming the judgment of the U.S. District Court for the Western District of Wisconsin. The appeals court rejected Thompson’s argument that he had a reasonable expectation of privacy in the information captured by the recordings because once Thompson invited the informant into the apartment, he forfeited his privacy interest in those activities exposed to the informant.

And see…

U.S. v. Houston, 2016 U.S. App. 2121 (6th Cir. Feb. 8, 2016).

The Sixth Circuit Court of Appeals affirmed the judgment of the U.S. District Court for the Eastern District of Tennessee, determining that where government agents obtained video footage of Rocky Houston’s possession of firearms at his rural farm, suppression was not warranted under the Fourth Amendment. The court found that Houston had no reasonable expectation of privacy in the video footage, which was recorded by a camera located on top of a utility pole and captured the same views as passersby on public roads.

Computer Search by Technician

U.S. v. Tapley, 2016 U.S. App. LEXIS 2020 (1st Cir. Feb. 5, 2016).

The First Circuit Court of Appeals affirmed the judgment of the U.S. District Court for the District of Maine, ruling that a computer technician acted as a private individual and not as an agent of the government in searching John Tapley’s computer. The court therefore determined there was no Fourth Amendment violation.

State Legislative News

The California Assembly passed a bill to regulate the daily fantasy sports (DFS) industry. AB 1437 would require all DFS operators to be licensed and sets up requirements for operators, including data security obligations and protections for players. The bill has been forwarded to the Senate.

The Maryland General Assembly overturned Governor Larry Hogan’s veto of a bill requiring online hotel-booking services to pay state sales tax on the price of hotel rooms, rather than on lower prices negotiated with hotels. Pursuant to the state constitution, SB 190 became law.

The Utah Senate Passed a Bill Requiring Computer Technicians to Report Child Pornography. HB 155, already passed by the House, would make failure to report a misdemeanor. The bill would provide immunity against civil lawsuits for technicians who erroneously report in good faith. Since the Senate made minor changes to the bill, it was sent back to the House for reapproval.

Cybercrime Initiatives in the Attorney General Community

Arizona Attorney General Mark Brnovich announced that Vincent Collins was sentenced to 35 years in prison after pleading guilty to two counts of sexual exploitation of a minor and one count of attempted sexual conduct with a minor. Collins admitted to sexually abusing a child and taking pictures and video of the abuse which he later distributed online. A forensic analysis of Collins’ computer by Immigration and Customs Enforcement’s (ICE’s) Homeland Security Investigations (HIS) revealed thousands of images and videos of child pornography. Collins will be on lifetime probation upon his release from prison. Assistant Attorney General Joseph Waters prosecuted the case.

Arkansas Attorney General Leslie Rutledge announced that John Herndon was sentenced to 40 years in prison after pleading guilty to 30 counts related to child pornography. Herndon had been arrested after a search warrant was executed by Attorney General Rutledge’s Cyber Crimes Unit. Herndon must also register as a sex offender.

California Attorney General Kamala Harris and Placer County District Attorney R. Scott Owens announced that Riley Bangerter, Sr. was arraigned on 11 charges of identity theft in a case of cyber harassment. Bangerter was arrested after Attorney General Harris’ eCrime Unit found he had superimposed images of his ex-wife onto child pornographic images and posted them online with her personal identifying information.

Florida Attorney General Pam Bondi’s Office of Statewide Prosecution announced that Denis Kutsayev, Tamara Kutsayeva and Renat Kutsayev were arrested on charges of title and odometer fraud. They advertised used cars on Craigslist and, according to the Florida Highway Patrol’s Bureau of Criminal Investigations and Intelligence, defrauded customers by removing the word “rebuilt” from the title of salvaged vehicles and altering the mileage on the title or rolling back the odometer. If convicted, Denis Kutsayev faces up to 85 years in prison; Tamara Kutsayeva, up to 55 years; and Renat Kutsavev, up to 10 years. The Office of Statewide Prosecution will prosecute the case.

Kentucky Attorney General Andy Beshear announced that Daniel Maresca pled guilty to two counts of possession of child pornography. Maresca was arrested by Attorney General Beshear’s Cyber Crime Unit after a search warrant executed at his home and the ensuing forensic examination found child pornography images. The case stemmed from a tip received from the National Center for Missing and Exploited Children (NCMEC).

Massachusetts Attorney General Maura Healey announced that State Police assigned to her office and the Walpole Police arrested Michael Kickham, implementation coordinator in the Administrative Office of the Juvenile Court, on one count of possession of child pornography. The investigation began after information was received from NCMEC about an email account that was allegedly viewing child pornography, and the email address was traced to Kickham. Search warrants were executed at Kickham’s residence and at his office, and devices seized revealed the existence of alleged images of child pornography.

Michigan Attorney General Bill Schuette charged Michael Skupin will six counts of possession of child pornography, a four-year felony; five counts of larceny by conversion, a five year felony; and one count of racketeering/conducting a criminal enterprise, a 20-year felony; for allegedly running and promoting a Ponzi scheme. Skupin allegedly recruited investors in his “gifting scheme” in which participants were paid out of new investors’ money until there were no more investors and most investors lost all of their money. Skupin’s laptop was searched pursuant to the Ponzi scheme investigation, and investigators discovered child pornography.

Mississippi Attorney General Jim Hood announced that Keneth Peal was sentenced to 20 years in prison, with five years to serve and the remainder on post-release supervision, after he pleaded guilty to one count of possession of child pornography. Peal had been arrested by Attorney General Hood’s Cyber Crime Unit and the DeSoto County Sheriff’s Office. Peal must also pay $1,000 to the Mississippi Children’s Trust Fund and $1,000 to the Mississippi Crime Victim’s Compensation Fund and register as a sex offender. The case was prosecuted by Special Assistant Attorney General Brandon Ogburn of the Unit.

Acting New Jersey Attorney General John Hoffman announced that Laquanda Tate, a former senior payroll clerk for the New Jersey Department of Human Services (DHS), was sentenced to 364 days in jail as a condition of three years of probation after pleading guilty to third-degree charges of simulating a motor vehicle insurance identification card and theft by deception. Tate used her work computer to generate false insurance cards for herself and others and stole public assistance benefits by creating false documents to claim childcare expenses. She was also ordered to perform 30 days of community service and pay full restitution of the $5,000 in public assistance benefits she received. The Division of Criminal Justice and DHS investigated the case. Deputy Attorney General Jonathan Gilmore of the Division’s Corruption Bureau prosecuted the case.

New Mexico Attorney General Hector Balderas’ Office held a cyber bullying and cyber safety training for high school students, parents and teachers. The training was conducted by Attorney General Balderas’ special agents and community outreach staff.

New York Attorney General Eric Schneiderman released “Obstructed View: What’s Blocking New Yorkers from Getting Tickets,” a report on the results of an investigation into the concert and sports ticket industry. The investigation found that 54 percent of tickets for major entertainment events are never made available to the general public, but are reserved for industry insiders or “pre-sale” events for non-public groups. In addition, it was found that ticket sellers like Ticketmaster regularly added fees of more than 21 percent of the face price of the ticket, and third party brokers reselling tickets on sites such as StubHub and TicketsNow average margins of 49 percent above face value. Some ticket brokers were found to be using illegal specialty software called “ticket bots” to quickly purchase large amounts of tickets and resell them at a significant markup. The report was a collaborative effort of the Bureau of Internet and Technology and the Research Department.

Oklahoma Attorney General Scott Pruitt announced that Matthew Hughey has been charged with one count each of distribution of child pornography, possession of child pornography and violating the Oklahoma Computer Crimes Act. Pursuant to a cyber tip, Attorney General Pruitt’s agents, the State Bureau of Investigation and the Greer County Sheriff’s Office executed a search warrant at Hughey’s home, finding child pornography on his tablet. If convicted, Hughey faces up to 45 years in prison and fines up to $55,000.

Pennsylvania Attorney General Kathleen Kane’s Child Predator Section and the Weatherly Police Department arrested James Kessell on 12 counts of possession of child pornography and one count each of distribution of child pornography and criminal use of a communications facility. The case will be prosecuted by Deputy Attorney General Rebecca Elo of the Section.

Rhode Island Attorney General Peter Kilmartin proposed “ISP Subpoena Expansion” legislation that would require Internet service providers (ISPs) to disclose subscriber account information, including name, IP addresses and telephone numbers associated with the account, upon proper service and with certification under oath by the Attorney General or State Police that the information is necessary for an official criminal investigation. HR 5742 applies to cases involving online impersonation and the electronic dissemination of indecent material to minors.

Vermont Attorney General William Sorrell announced that Bobby Bushey was arraigned on five felony counts of Promoting a Recording of Sexual Conduct by a Child and one count of possession of child pornography. Bushey allegedly obtained and distributed child pornography using peer-to-peer file-sharing programs. The charges stem from an investigation by Attorney General Sorrell’s Office, the Vermont Internet Crimes Against Children Task Force, the State Police, the Burlington and South Burlington Police Departments and Homeland Security Investigations.

Hedda Litwin is the Editor of the Cybercrime Newsletter and may be reached at 202-326-6022. The Cybercrime Newsletter is a publication of the National Association of Attorneys General. Any use and/or copies of this newsletter in whole or part must include the customary bibliographic citation. NAAG retains copyright and all other intellectual property rights in the material. For content submissions or to contact the editor directly, please e-mail

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