use of these search robots and that the searches improperly taxed Register.com's server capacity. These holdings gave the court license to expand the applicability of trespass to chattels to computer networks even further. In Oyster Software v. Forms Processing (2001), the Northern District of California determined that a plaintiff need not demonstrate any physical interference with a server at all to sustain a trespass to chattels claim and consequently denied the defendant's motion for summary judgment, even though there was no evidence of damage to the plaintiff's computer system. Although Oyster conceded that there was no evidence that the defendant's activities had interfered in any way with the functioning of Oyster's computer system, the court nonetheless denied FPI's motion for summary judgment. According to the court, following the decision in eBay, plaintiffs only need to demonstrate that the defendant's actions "amounted to a 'use' of Plaintiff's computer," and the court determined that copying the metatags amounted to a use. These cases indicate that, at least in California, a plaintiff did not have to demonstrate any kind of actual interference with the computer system to successfully claim trespass to chattels. The backlash against the tort's expansion However, some courts subsequently limited tort claims for electronic trespasses, in that a complaining party may be unable to recover for lack of real harm if the party did not suffer any tangible damage to their property. The Supreme Court of California reversed the trend exemplified by Oyster in the seminal case Intel Corp. v. Hamidi (2003), reaffirming the need for a demonstration either of actual interference with the physical functionality of the computer system or of the likelihood that this would happen in the future. Although Intel conceded that Hamidi's emails caused neither physical damage nor any disruption to their computer system, they alleged that the economic productivity lost due to the disruption caused by the emails could sustain a trespass claim. The Supreme Court of California disagreed, holding that the tort does not extend to claims in which the electronic communication involved "neither damages the recipient computer system nor impairs its function." In reaching this conclusion, the court criticized the understanding of eBay advanced in Oyster, explaining that previous cases in which courts have found trespass to chattels in the electronic setting have involved either "actual or threatened interference with the computers' function." To that effect, the court in Oyster misconstrued the holding