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Name: People v. Kozlowski
Case #: A091586
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 03/04/2002
Subsequent History: Rehg. denied 3/28/02, rev. denied 5/15/02.

The issue presented of first impression was whether a PIN code is “property” for purposes of a kidnapping for extortion conviction. Cases and statutes define the term “property” in the context of theft-based offenses as the exclusive right to use or possess a thing or the exclusive ownership of a thing. A PIN is a code number that operates as a means of account access. Thus, the PIN is property because it implies the right to use that access code — and to access the funds in the related bank account by means of that code. The PIN code can be characterized as intangible property.