Does the Computer Fraud Act Apply to ‘Dumbphones’?

While this Court does not disagree that unwanted text messages, like spam e-mail, are an annoyance, whether receipts of such messages can establish a civil action under the CFAA is, of course, a different question. Czech v. Wall Street on Demand, Inc. 674 F.Supp. 1102, 1106 (N.D.Minn. 2009). Anti-spam (e-mail and text) lawsuits and legislation are legion: a flurry …