Criminal computer trespass statutes in the United States usually include a specific element requiring proof beyond a reasonable doubt that accessing the computer or computer network was "unauthorized." See, e.g., 18 U.S.C. §1030(a)(2); N.Y. Penal Law §156.05; Cal. Penal Code §502(c)(7); Pa. Code 18 §7611. Unfortunately, that phrase continues to cause litigation, with the U.S. Supreme Court recently hearing oral arguments about its scope in the case of Van Buren v. United States, 940 F.3d 1192 (11th Cir. 2019). Van Buren specifically concerns the meaning of access without authorization, that is, "exceeds authorized access" under the federal Computer Fraud and Abuse Act (CFAA), 18 U.S.C. §1030.