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Copyright (c) 2002 The American University Law Review
American University Law Review


October, 2002

52 Am. U.L. Rev. 339


Erin M. Shoudt*


On February 23, 2001, Abraham Abdallah, a busboy from Brooklyn, New York, was arrested for using the Internet at public libraries to steal the identities of more than 200 of the wealthiest business moguls in the United States, including Steven Spielberg, Oprah Winfrey and Ted Turner. 1 After acquiring the celebrities' social security numbers, credit reports, account numbers and addresses, Abdallah accessed their credit card and investment accounts and made an estimated $ 100 million worth of purchases on the Internet. 2 In April 2001, a California court sentenced a man to 200 years to life in prison for using the identity of Tiger Woods to buy $ 17,000 worth of goods, including a television and a luxury car. 3 On June 5, 2001, after a request from the Governor, the Florida Supreme Court issued an order to impanel a grand jury to investigate the growing problem of identity theft. 4 Currently, numerous legislative bills addressing the privacy of personal data are pending in the U.S. Congress. 5 Significantly, the U.S. Supreme Court decided its first case involving identity theft in November 2001. 6

These legislative and judicial responses reflect the growing national concern over privacy of personal information and identity theft. 7 Identity theft is defined as a crime where "an individual appropriates another's name, address, social security number, or other identifying information to commit fraud." 8 Recently, the U.S. Attorney's Office recognized identity theft as "the crime of the new millennium." 9
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