Intel Corp. v. Hamidi

Summary

The Supreme Court of California held that sending unsolicited e-mails through Intel's computer system did not constitute trespass to chattels because the messages caused no damage to the system, impaired no functionality, and deprived Intel of no use. The court concluded that California trespass-to-chattels law requires injury to the personal property or a legally protected interest in it. The court reversed the injunction against the former employee's mailings.

Holdings

1. Under California law, trespass to chattels does not encompass an electronic communication that neither damages the recipient computer system nor impairs its functioning or otherwise injures the possessor's legally protected interest in the property.
2. California common law should not be expanded to impose trespass liability for otherwise harmless electronic communications merely because they pass through a privately owned computer system.
3. Intel was not entitled to an injunction because it failed to show actual or threatened injury to its computer system or legally protected property interest.

Questions Presented

1. Whether sending unsolicited electronic communications through Intel's computer system, without causing physical damage or functional impairment to the system, constitutes trespass to chattels under California law.
2. Whether California common law should be expanded to recognize a trespass claim based on harmless electronic communications whose contents distract or offend recipients.
3. Whether Intel was entitled to injunctive relief without proof of actual or threatened injury to its computer system or legally protected property interest.

Disposition

reversed