MLM 770                                      Law and the Internet                 Trimester 1, 2012

Assignment 2 – ‘Report and recommendations’ paper

Choose one of the following topics:

1. With reference to appropriate cases and other materials discuss the
proposition that parental and self-selection strategies are preferable to
censorship or filtering of content distributed over the internet.

2. The television, music and film industries in Australia are pushing for the
introduction of legislation requiring ISPs to police the file sharing
activities of their users. However, because such legislation has only been
introduced in other countries during the past two years, there is no
evidence to indicate that such legislation has any effect in preventing or
deterring copyright infringement. For the moment at least, it seems that
entertainment providers have no choice but to rely on litigation against
ISPs established blatantly for the purpose of assisting copyright

3. Discuss the proposition that the Privacy Act 1988 (Cth) is drastically in
need of amendments in the light of the technologies that enable personal
information to be readily located, disseminated and accessed globally.

4.   To what extent is cyber-crime much exaggerated and really only
represents more of the same in terms of the challenges it poses to the
courts and other law enforcement agencies?

‘Report and recommendations’ paper format

The format required in this assignment is flexible. The ‘Report and
recommendations’ format is seeking a response offering some insight,
through research, into the chosen topic while also affording the author the
opportunity of adding to the discussion through innovative suggestions to
address deficiencies that may have been identified through the research
into the topic.

For example, the recommendations can be individual propositions or
positions already proposed by other authors that may be supported or
rejected in the submitted paper.

The topics chosen for the assignment are areas that have major reports and
wide general and case commentary available.

Importantly, your research should go well beyond the individual cases and
reports through the use of relevant academic sources such as textbooks and
journal articles.

Kimberley Evans, The age of online copyright infringement 2010 13 (7/8) Internet Law


General information

 The paper is worth 50% of the final mark.

 The maximum word length is 5000 words (excluding footnote references
and the bibliography).  Any words over 5000 will not be assessed.

 The paper is to be presented in 12 font with 1.5 line spacing.

 The paper is to include a bibliography (not included in word length).

 The due date is 19 May 2012.  Extensions will not be granted except for
unforeseeable events, such as unexpected medical illnesses.  Extensions must
be obtained in writing – please email me at

 An assignment that is submitted late without an extension will be subject to a
penalty of 3 marks per 24 hour period (or part thereof) following the
assignment deadline.

 The citation and referencing must comply with the Australian Guide to Legal
Citation 2
ed, available from  If
the source is not directly covered in the AGLC, you should use your ‘best
estimate’ as to how to reference it, by having regard to the referencing style
used by the AGLC and similar sources.

 Students should ensure that they properly attribute and reference all source
materials.  Assignments will be scanned for plagiarism using the Turnitin
Plagiarism Detection Software.  Please refer to the unit guide for further
guidelines relating to avoiding plagiarism and collusion.

Submission information

 Submission is by electronic means only.

 All students must submit their assignment to the DSO Assignment Drop
Box by the deadline of midnight, 19 May 2012.

 Each submitted copy of the assignment must be accompanied by an
assignment declaration form which must be copied into the beginning of the

 The copy should be submitted as a Word (.doc) document or Rich Text
Format document (.rtf).

 You must include a word count (excluding the footnotes and bibliography)
at the beginning of the paper.
Learning Outcomes
1. The general objective is to assist students to continue developing legal
research and writing skills by undertaking a structured research task while
focussing on a particular topic within this unit.
2. Students will be assessed against the following criteria:

a. Your ability to clearly identify and articulate the essence of the topic
and its requirements;
b. Your ability to structure the paper in a logical way;
c. Your ability to find and use appropriate primary and secondary legal
resources, including international resources;
d. Your ability to engage in sound legal analysis;
e. Your ability to communicate your legal analysis in writing;
f. Your ability to use various legal writing styles beyond the merely
descriptive (i.e. analytical, conceptual and comparative writing)
g. Your ability to correctly cite and reference the materials using the
Australian Guide to Legal Citation 2


Challenges related to Cyber Crime and its exaggeration


From past few years, much chaos is created by so called ‘Cyber Crimes’ across the globe. In general words cyber crime is a crime committed on or with the help of computers.  Cyber crime gained much popularity due to complexities attached to it. Many computer and scientific analysts are of the opinion that normal penal laws of any country are not sufficient enough to deal with these computer related crimes, so, there is a need of efficient and exhaustive legislations. On the other hand it seems that much attention is paid to this issue than what it actually requires. It is just troubling the courts and other national organizations in their process of justice as compared in other offences.

This report is an attempt to clarify the growing apprehension of Cyber crime, on internet and truth attached to it. Starting with the importance of internet in our daily life we will move on to its dark side of this, where advance technologies are being misused to do illegal acts. The person doing this can easily hide their names and identity behind the domain name. On the same note people also do not have complete privacy related to the information stored in their computers. Those who think that they are safe doing any activity, legal or illegal are wrong because the service providers who have the information related to the users may be called by the courts for the discovery of that person engaged in such things. Next, the report canvasses the difficulties faced by the courts in dealing with such wrongs or offences on internet and recommendations to solve them. This report also provides the data on how the statistics of cyber crime are exaggeratedly shown by the investigatory authorities which is creating a false apprehension in minds of internet users. This in result causing loss in their internet based businesses.

Computers and internet in our daily life

Charles Babbage of England is considered as the father of modern computer who in 19th century conceived the idea to develop computers. However, this idea did not materialize immediately and took nearly a century to develop a digital computer.  A significant development in the history of computer technology took place in 1950 when programmable and general computers were launched. The era of automation has completely changed to era of information. The internet is a worldwide network of thousands of computers connected with each other and providing an expensive and information rich data’s. Internet is the quick facilitator of ideas. It provides the affordable and secure way to link people spontaneously by connecting their computers across organizational borders. It is much easier to communicate through internet. We can reach easily to the person to whom it was difficult before this to reach. In a nutshell we can say that the revolution brought by the computers and internet is beyond the control of human beings and became a problem despite of its much importance. People searching for academic and commercial papers on internet can find a plethora of audible dictionary, articles, newspapers, images and government links.[1]

This may be very exciting for some people who want to communicate and share their progressive ideas with other people but there are also those internet users who are using the technology to spread hatred in the society by publishing or posting some objectionable things. In a way we can say that internet along with its usefulness brings a hike in illicit acts and wrongs done by the person on much large scale i.e. on World Wide Web.

Crimes on internet: Cyber Crime

The dark side of this computer revolution is the crimes committed with the help of these technologies popularly known as Cyber Crimes. In defining cyber crime we need to be very careful as it is related to various national and international ideologies. We must be very specific in fixing the scope of cyber crime so that it may not be so large to cover every aspect related to the computer or it should not be so small to leave the relevant issues behind. In general term a cyber crimes are the crimes committed on internet through Computers. These computer crimes may involve Violative and non- violative acts related or with the help of computer. Crimes on internet may be in many forms such as, fraud, scams, money laundering, data hacking, smuggling, suicide assistance, prostitution, viruses, cyber and actual terrorism. Broadly we can categorize them in three, crimes which are committed with the help of computers as a tool, such as those offences on person and property, second in which computers are the victim or effected by such acts like the virus attack, hacking and illegal uses of computer programs and third, where the computers are incidental to the crime such as where it is used for the storage of data and information in criminal transactions.[2] Crime against person may be sexual, including rape, child pornography and prostitution and non sexual such as defamation, theft, harassment etc. The most common non sexual offence committed by the offender from internet is of defamation.

Various examples of Cyber Crime

Defamation on internet

After the decision of US Supreme Court on the matter of public defamation in the case of New York Times v Sullivan, defamation has become a more defined and established offence.  Where often people want to complain about an offender who has no face of its own he is just hiding behind the anonymity of the ‘Screen Name’. Now it is very difficult in identifying the speaker unless the courts pressurize the service providers to disclose the name of the speaker. It would cost the plaintiff much lesser when the identity of the speaker was known than now when he has no knowledge that who is the speaker of such libelous statement about him. [3] In past ten years, the cases related to internet libel are evolving like a crop in the court rooms of every state. There are few cases which seem to provide guidelines for solving these matters and also problems faced by the courts.  In Melvin v Doe, an unknown person published some defamatory statement about a judge that he is not worth for the position of a judge. The judge then brought a suit for the discovery of identification of that person and holding him liable for such statement. The court in that case held that it is required for the plaintiff to prove that the identity of defendant is very important, relevant and important for the case and that it is difficult for him to identify him and also that the identity of the defendant is crucial for the case of plaintiff. These three layer test is very important for any body claiming to be defamed by the libelous statement by the defendant. This decision of the court was held to be more significant than the judgment given in Ampex case that the identity of the defendant was not relevant for the plaintiff. The three part test was the perfect balance between the rights of the speaker and the rights of the plaintiff claiming for the defamation without putting him under any kind of burden.[4]

Homicide (causing death of another person)

It was always presumed that causing some ones death is the phenomena of real world but from last decade it is made possible by the internet for example, it is possible to hack the computers of a hospital and alter the data including the history of a patient. Hackers can easily modify the amount and dosages of medicine that should be taken by the patient and can cause him to take the lethal doses.  This could result in his/her death. This is the most common crimes-murder which is done in an uncommon way. Here the computer is just used as a tool to commit the crime, in a way it replaces knives, guns and other weapons.

Facilitation of Prostitution

It is very easy to get and exchange any information related to any thing on internet. It is also similarly easy for any person to get some illegal stuff on it. There are many websites on internet which are advertising, promoting and marketing prostitution on internet. They are not even bothered about national or international laws. The situation becomes worse when some countries do not consider showing of obscene material on internet as a crime. There are many people involved in this business spending a lot of money secretly. This makes the obscenity to spread all over the world.[5]


Today the entire world is affected by the evil of terrorism. This is the established crime which is now largely assisted and conducted by computers. The terrorists not only communicate and advertise, infact they can entirely conduct the terrorist act through computers. Many instances are there, when in 1999, where the terrorist considered being Russian hackers, hacked the computers of Pentagon, this is the evidence of terrorists hacking computers.

Harassment and Hate speeches

These are the offences committed on internet by publishing or posting some statements by particular group of person spreading hatred against them in the society. It is true that there is freedom to express one’s own ideas and views on internet but this freedom are also being used against other by the hate groups. They are active on the internet since many years as internet in the most inexpensive source to communicate their views. This is really a big problem for any domestic criminal law even if it has laws for cyber crime.

There are some crimes which affects the reliability and confidentiality of computer system. In these computers are itself the victims


Viruses are the code that attaches itself to the programs in the computer and reproduces it self which causes the destruction of the important files of that computer. First PC virus was the ‘Pakistani PC viruses detected in 1986.  According to the computer experts, almost 200 Viruses are created in every month across the world but all viruses are not such dangerous as the ‘Love Bug’ was. In early 2000, all the computers across the globe were hit by the super virus called ‘Love Bug’. It was so quick that within few hours of its emergence it affected almost all computers. The virus was designed in such a way to delete and destroy all the files of the victim’s computer and disseminate itself, according to a report effected at least 27,000 computers it its very first hour.[6]

Including the computers of House of Lords, these love bug virus, caused the forced shut down of the systems in many others such as of Ford Motors, Dow Chemical Company etc. After investigations it was detected that the Bug came from Philippines. The Phillippinian and US team were sent to investigate and identify the person who made the virus to disseminate. Many problems were faced by the investigatory team because of the lack of cyber crime laws in Philippines. The accused, Onel Da Guzman, was identified but there were no laws to hold him guilty of dissemination of viruses. Anyhow the teams managed to get an arrest warrant from the court and caught the man.  Eventually the charges on him were dropped by the department of Justice because the charge of credit card fraud was not sufficient for holding him guilty.

This entire episode of ‘Love Bug’ is an eye opener for those who are very much concerned about the cyber crimes because it showed that we are grossly lacking behind in making the laws on cyber crimes. The main problem is the lack of cyber crime specific laws and their proper implementations. There is lack of cooperation between national and international bodies to deal with these issues. Because of these issues cyber crime is a challenge of every nations and organization. As internet caused the national and international boundaries permeable, cyber crime is not a phenomenon to be dealt by a single nation. There must be agreements between the countries who are technically advanced and also who are not so to take some solid steps in dealing with these crimes.


Hacking may be in the form of accessing which means entering into the network which is meant to be for private use or changing the content of another’s personal website. Many computer users think that hacking is not a crime and pretty much a fun thing, but it may cause a severe threat to the privacy and affect the E- commerce. As per the report of advisory group on cyber crimes there are more than 10,000 hackers in the world who are divided in three categories, the black hackers who secretly and privately invades the computers of others, white hackers who on the request of some organizations enter into the computers of others and last Grey hackers who are doing this in both ways.[7]  There one most infamous group of hackers is from America known as “the cult of the Dead cow” or CDC and individual hacker is Kelvin Micknit who was sentenced for five years for hacking the computers of most famous multinational company including Motorola. Where much of the hacking is done in the name of fun, some hackers do it for committing some very serious crimes such as, stealing money from ones account, or getting details of some ones credit cards or black mailing by tracing the mail list of that person.


One of the most common forms of offence done through internet is of fraud. It includes the tricks to make the victims provide their password to access their accounts. They usually do this by sending a customer related e-mail asking them to re-issue or confirm their passwords on the link given where they take the confidential information. In America in 2003 there were number of bank customers who were the victims of fraud on them. Any bank of financial institution where so ever it is can never ask any customer to disclose their information like this.

Another fraudulent practice known as ‘Cramming’ in which the customers are charged for some extra service provided on the actual service. It was in the case where a company runs a network in which one of them includes pornography sites also which provides free subscription to the customer on providing their credit card details to confirm that the person is above 18.

The problem often faced by the penal legislation of many countries is to accommodate these computer offences.  Another problem in most legal system is related to theft because law recognizes theft only when it is proved to be on tangible thing. In cyber crimes the object of theft is data and information of computer which are intangible.

Industrial Espionage

With the advancement of technologies all businesses and transactions are carried through internet. Computer serves as very good storage for information in industrial area. The most common form of crime committed in industrial area is in the form of downloading data and information from one computer of any company and sent as an e-mail to another company which may be competitor of that company known as ‘Industrial Espionage’. This is most classical crime which is also criminalize under all existing criminal system.[8]

Cyber Crime Dilemma: an analysis

It will not be wrong to say that data are more valuable than money because once we spend money it is gone, but we can store the data and use it again and again to earn more money. This growing ability to reuse data for banking profits and financial activities has provided much space for the cyber criminals for their illicit activities. Today cyber criminals are not confined to particular jurisdiction but they are operating from everywhere in the world and making money by using stolen data again and again. The organizations in lack of proper mechanism to acknowledge, address and resolve cyber crime are the big reason for this underground growing business.

The cyber crimes are different from any other kind of crime side by side it is also a matter of concern for the justice department because of few reasons such as, they are very easy to be learned, they need very less resources as compared to its potential damage, they are done in a particular jurisdiction without the presence of the person doing it, also they do not seem to be much illegal, hence the police department faces much difficulty in framing the charges against the culprit. Cyber criminals can easily defy the jurisdictional realm of the so called powerful nations by attacking their computer system from anywhere in the world and passing it to other countries. It dramatically increases the pressure on investigating and prosecution teams of cyber crime. Till now much development has been brought by the countries but there are still few nations who are not very active on the issues of cyber crime. They really need substantial changes in their laws for controlling these crimes and information security.

We can not solely blame the criminal minds of the culprits albeit it is our deep love for the developing technologies which gives immense opportunities and space for these activities. There are many developments which are responsible for the cyber crime waves across the nations such as:

a. tremendous growth in communication devices, networks and users

b. constant online communication and social networking generated vulnerabilities creating more opportunities for cyber crimes.

c. Online commercial transactions, banking, investing and intellectual property distribution provides many opportunities for fraud, stealing and other cyber crimes.[9]

These crimes have created a big problem for the courts, police and other governmental organizations. They are the real victims of cyber related crimes because it is really annoying for them to investigate about the identity of the criminal who is in some other country may be anywhere in the big world. It also creates problems as they are beyond the actual jurisdiction where the crime is reported to affect the victim.

Challenges on procedural rules and law enforcement

The main problem faced by the countries is that they do not have proper laws to deal with such crimes. In fact, criminalizing cyber crime is not enough; the real issue arises in proving those charges. Other challenge is of searching and seizure of the evidence and also keeping them in such way that they must not destroy and remain in the condition in which it should be presented before the court of law. There is another question that whether the authorities and court may be empowered to ‘Hack’ any system in order to find out the criminal.[10]  All the evidence of a computer can be relied and are admissible before the courts of law as that of the normal evidences but main problem is that these are very volatile and can be easily altered. In such situation there is need of a well tested computer forensic. Also there is a need of such procedural article which authorizes to search and seize the evidence where it is reasonably believed that some illegal activities are going on.

For a better enforcement of law on cyber crime, there is a need to be sure that our police have all the necessary resources and expertise over these to handle the investigation. This is the challenge in enforcing the law because the subject of these new laws may be not very known to them hence they need to deal expertly. Not only police but the prosecutors are also trained how to deal with the electronic evidences. Also they should be trained to frame such warrants so that it allows police to go any possible area keeping in mind the essential human rights of the accused. May be there is no entire new law on cyber crime rather they have apply the existing procedural laws on such circumstances.  Many people are of the opinion that there must be training for police and prosecutors for the enforcement of these laws. In my opinion not only police and prosecutors but the judges must also be trained for dealing with these cyber crime incidents.

Another challenge impose by cyber crime on governmental authorities is the costs related to it. From a research in 2011 it has been established that recovery and detection of cyber crime is the most costly internal activities. It costs around 45 percent of entire internal activities cost of a nation. Its cost further increases depending upon the type of cyber crime.  The costs associated with cyber crime effects all the other industries.

Statistics of Cyber Crimes: Reality or Exaggeration?

From past 10 to 15 years, cyber crime gained much spotlight and becomes the most discussed topic. While the other businesses are hit by recession, the cyber crime industry is still blooming. As per the economists, cyber crime is the easy way to earn money just by spamming or stealing passwords. It is not that true, it is not easy for any one to do all these activities except few.

It is true that the ‘Cyber Crimes’ created much terror in our society but there is no need to be much worried. The reason behind this is that, Cyber crimes although a threat but not that big problem today as we think and second the threats that is shown by governmental authorities are more or less the product of their own imagination. These estimations are carried out by the surveys of consumers and businessmen who are affected by these crimes, in lack of any real or hard data. In estimating the loss caused by cyber crimes across the nation the authorities use some very bad statistic methods and surveys. According to a report, it was estimated the loss of 114 million in business and consumer area due to cyber related illegal activities; this is really a data which do not seem to be reliable.[11] The survey is conducted on few people who suffered loss due to this and scientist and researchers scale it on overall population which really exaggerates their estimation. One of the post bad things about cyber crime statistics is that most of the time the victims are even not known that they have been attacked by this crime so how can be the estimated figure comes that large. For drawing any estimate related to any issue, there must be a group of people who are sufficient to represent the population. It was disclosed by a researcher that almost 90 % of the estimate in cyber crimes comes from the answers given by one or two person. A survey conducted by FTC in 2006 related to identity theft was answered by two businessmen only and it would have added on to approx. $ 37 billion over the estimate.[12]

But it does not mean that there is no problem, but we have to look into the real estimations not the exaggerated one. It is true that the problem exists but the question is that how big it is? It is definitely not the solution to only portray this issue as a big giant but to find out the right way to minimize such illicit activities. No doubts, that the efficient Law is the part of the answer but self help is also very necessary.


Securing our own network Information: Self help

Any individual or firm should try to secure their own systems and network informations by using more keys and passwords. The property owners themselves take steps to protect their property likewise; we also need to protect our informations. It is not the fault of police or laws if we keep our houses open without locking the door. Enforcement of even more powerful laws can not help us. Hence this is primary responsibility of the network users or firms to secure their data themselves. Their responsibility becomes much significant when they belong to a country where there is no such law to deal with cyber crimes.[13]

Assurance from government about the applicability of existing laws to cyber crimes

Governments should insure their people that the criminal laws of that country are sufficient to deal with these cyber crimes and start working on the new advanced laws. It is the national government of any country who can regulate the criminal behavior of that country. Many nations in the world have now updated their laws on cyber crime after few instances of cyber crime hitting the IT sector badly such as the attack of ‘Love Bug’ made America to enforce their cyber laws effectively.

Governments, firms and civil societies should work together

For strengthening of legal framework dealing with cyber crime it is important that government, civil societies and firms should work together. To prosecute the cyber crime, there is need of crossing borders and jurisdictions. Hence there must be collaboration between every authority to cooperate.


Due to the week penalties in some of the crimes it is effective on the criminals and deterrence of crimes. So the latest updated laws must have the penalties to punish the criminals in real sense.

Commercial Solutions

Recently with the introduction of various filtering device, it becomes very easy for the network owners to block the site for further usage. With the help of this Government is not required to get into cyber crime matter this filtering device is sufficient to keep the hackers or criminals away. This helps from domestic level where parents or teachers wanting their kids not to watch or go through those objectionable things they can use that filter.


Crimes are the inherent part of human nature, regardless of individual’s culture, economy and status. Hence every nation is trying their best to reduce or fix limit of these crimes. However the statistics are evident that the crime rates are increasing with the help of advanced technologies. These technologies have given rise to the crimes known as internet crime or cyber crimes. These are different from the other conventional crimes as there is no limit of boundaries and jurisdictions. But at the same time it troubles the investigatory authorities and courts the same way the other crimes does. From past few years this internet topic has raised much hue and cry every where which is not actually needed. We have seen from the data in report above, how they are being exaggerated beyond reliability. It is true that cyber activities are affecting our societies negatively but at the same time they are also a boon for us. Relying on these data’s and exaggerated stats people will not going to stop depending on these.  Internet is, without any doubt is the source of ample of information and progressive ideas.

The importance of computers in our daily life will obviously going to increase in future, hence,  there is an urgent need to secure the integrity, admissibility, confidentiality and reliability of the computer networks.





















  1. Robert MacMillan, ‘U.S. Courts Decline to Block Net Hate Speech’, NEWSBYTES NEWS NETWORK, Nov. 8, 2001
  2. Dave Wilson, ‘Ruling Backs Anonymity of Net Messages’, L.A. TIMES, December 11, 2001
  3. Allison Stiles, Everyone’s critic: Defamation and anonymity on the internet, [2004], viewed on 17th May 2012 from
  4. Melvin v. Doe, 49 Pa. D. & C. 4th 449, 477 [2000].
  5. Fast-spreading Virus Hits U.S., Asia, Europe, USA Today, [2000], viewed on 17th May 2012 from
  6. Susan W Brenner, ‘Cybercrime Investigation and Prosecution: the Role of Penal and Procedural Law’, University of Dayton School of Law
  7. Rizgar Mohammed Kadir, The Scope and the Nature of Computer Crimes Statutes ‐ A Critical Comparative Study,  College of Law and Politics – Department of Law, Salahaddin University,
  8. Victor Adebanjo, ‘crime on Net’, viewed on 17th May2012 from
  9. Deloitte, ‘Cyber Crime: A clear and present danger’, [2010], viewed on 18th May2012 from


  1.  Walden in Chris Reed and John Angel, Computer law, Oxford University Press, Fifth edition, 2003, P. 295.
  2. Conference Booklet on cyber Crime, University of Morocco, [2007], viewed on 17th May 2012 from


  1. Constantine von Hoffman, ‘Cyber Crimes stats are vastly exaggerated’, [2012], viewed on 18th May 2012 from
  2. The Cybercrime Wave That Wasn’t, By DINEI FLORÊNCIO and CORMAC HERLEY, Sunday review, NY times, [2012] from


  1. Peter Sommer, EVIDENCE IN INTERNET PAEDOPHILIA CASES, Computer and Telecommunications Law Review, 2002, 8(7), 176-184.
  2. Mac. Connel International,  Cyber Crime and punishment?, [2000], viewed on 18th May 2012 from,






[1]  Robert Mac. Millen, U.S. Courts Decline to Block Net Hate Speech’, News Bytes News Network, Nov 8, 2001.


[2] Dave Wilson, Ruling Backs Anonymity of Net Messages’, L.A. TIMES, December 11, 2001


[3]  Allison Styles, ‘Everyone’s critique: Defamation and anonymity on Internet’, [2004].

[4] 49 Pa. D. & C. 4th 449, 477 (2000).

[5] Walden in Chris Reed and John Angel, Computer law, Oxford University Press, Fifth edition, 2003, P. 295.

[6] “Fast-spreading Virus Hits U.S, Asia, Europe”, USA Today, June 7, 2000.

[7] Susan W Brenner, ‘Cyber Crime investigation and Prosecution’, University of Dayton School of Law, 2002.

[8]  Rizgar Mohammed Kadir, ‘The scope and nature of cyber crime statutes: A critical comparative study’,

[9]  Deloitte, ‘ Cyber Crime : A clear and present Danger’,2010.

[10]  Victor Adebanjo, ‘Crime on Net’,

[11]  Deini Florenceo, The Cyber Crime Wave that was’nt’, Sunday Review, New York Times, 2012.

[12] Constantine von Hoffman, ‘Cyber Crimes stats are vastly exaggerated’, 2012.

[13] Mac. Connel International,  ‘Cyber Crime and punishment?’, 2000


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