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Note 1: Regardless of this evidence showing that Rohn possessed many different forms of false identification, the court reversed Rohn's conviction because the government was unable to show that Rohn "knowingly possess[ed] with intent to use unlawfully or transfer unlawfully five or more identification documents"^'' as required by 18 U.S.C. § 1028(a)(3).^^ Note 2: n unlawful use because Rohn had not demonstrated a lawful one."^^ The court stated that the government tried to convict Rohn under a statute that Congress did not write, and that because the government did not technically meet all elements of the statute, the conviction had to be overturned. Thus, even though the government had charged an individual who had obviously stolen and used many different identities, the government was unable to convict this individual based on the technical language in the statute. Note 3: The U.S. Supreme Court agreed with the Petitioner, holding that the government must prove that a defendant knew that the "means of identification" he or she unlawfully transferred, possessed, or used did, in fact, belong to another person.'**^  Note 4: Thus, because the government could not prove that the petitioner technically knew that the identification numbers belonged to other people, the Supreme Court reversed the aggravated identity theft charges.'*'

Ten C's Rating: Currency: 13 Content:11 Authority:9 Navigation:9 Experience:10 Multimedia:3 Treatment: 10 Access:5 Miscellaneous:10 Total: 80 Good This articles explains the continuous rise of identity theft over the internet.

Ten C's Rating: Currency: 13 Content:14 Authority:9 Navigation:9 Experience:10 Multimedia:5 Treatment: 10 Access:5 Miscellaneous:10 Total: 85 Good

Note 1: Stealing someone's identity in the world of Facebook, Linkedin, Twitter and other social networks - allied with a sea of easily obtained name, address and associated data from a wealth of free and low-cost online sources - is now so easy that cybercriminals are even offering DIY kits to novice criminals. If that wasn't enough, online underground forums now act as a 'carder forums' where cybercriminals buy, sell and exchange identity and payment card sets for as little as $2.00 a time - rising to $6.00 if the identity on sale is that of an apparent high-flyer (e.g. a platinum card holder) located in the UK or premium income parts of the US such as New York City and Florida. Note 2: The carder forums - and the criminals who exchange data on them - have become highly sophisticated in the last few years, expanding their data-harvesting programs to encompass both legitimate and fraudulent e-commerce websites, as well as bribing members of low-paid staff in outsourced call centres, for whom $500 for a copy of their employer's database, or partial database, may be a highly enticing prospect. Note 3: There are even reports of some sites supplying users with their required CDs or DVDs (pirate versions, of course) and then selling the identity and card sets via multiple card forums. This is fraud monétisation and identity theft on a one-stop basis.