over a dispute with a client about an unpaid bill. The client reported this to the police who charged the programmer under Section 3 of the Act, with the outcome being a conviction by a magistrates court, with a conditional discharge given by the magistrate meaning that no punishment was applied on condition that the programmer did not re-offend. Latest situation Schedule 1 Part II of the Criminal Justice (Terrorism and Conspiracy) Act 1998 ('Conspiracy') amended Section 8 (relevance of external law), Section 9(2)(b) (British citizenship immaterial: conspiracy) and Section 16 (application to Northern Ireland). In 2004, the All-Party Internet Group published its review of the law and highlighted areas for development. Their recommendations led to the drafting of the Computer Misuse Act 1990 (Amendment) Bill which sought to amend the CMA to comply with the European Convention on Cyber Crime. Under its terms, the maximum sentence of imprisonment for breaching the Act changed from six months to two years. It also sought to explicitly criminalise denial-of-service attacks and other crimes facilitated by denial-of-service. The Bill did not receive Royal Assent because Parliament was prorogued. Sections 35 to 38 of the Police and Justice Act 2006 contain amendments to the Computer Misuse Act 1990. Section 37 ("Making, supplying or obtaining articles for use in computer misuse offences") inserts a new section 3A into the 1990 Act and has drawn considerable criticism from IT professionals, as many of their tools can be used by criminals in addition to their legitimate purposes, and thus fall under section 3A. After the News International phone hacking scandal in 2011, there were discussions about amending the law to define "smart" phones (i.e. those with Internet browsers and other connectivity features) as computers under the Act. Such an amendment might also introduce a new offence of "making information available with intent", i.e. publicly disclosing a password for someone's phone or computer so that others can access it illegally. In 2015, the Act was further amended by Part 2 sections 41 to 44 (plus others) of the Serious Crime Act 2015. The amendments The amendments to the Computer Misuse Act 1990 by Part 5 of the Police and Justice Act 2006 are Section 35. Unauthorised access to computer material, punishable by up to two years in prison or a fine or both. Section 36. Unauthorised acts with intent to impair operation of computer, etc. punishable by up