OPENRISK, LLC v. MICROSTRATEGY SERVICES CORPORATION
US Court of Appeals for the Fourth Circuit, Harris, Nov. 13, 2017,
Preemption – Federal copyright law preempts Virginia’s Computer Crimes Act with regard to “computer fraud” claims.

Federal Copyright Preemption – A state law is preempted by federal copyright law if: the work at issue is protected by federal copyright AND “the rights granted under state law” are “equivalent to” those protected by federal copyright.

From the Case: Because federal copyright prohibits unauthorized copying of a computer program and the VCCA prohibits unauthorized copying of a computer program, it is preempted by federal copyright law.