Conn. Crim. Jury Instr. 10.3-2

The defendant is charged [in count__] with trafficking in personal identifying information. The

statute defining this offense reads in pertinent part as follows:

a person is guilty of trafficking in personal identifying information when such person

sells, gives or otherwise transfers personal identifying information of another person

to a third person knowing that such information has been obtained without the

authorization of such other person and that such third person intends to use such

information for an unlawful purpose.

For you to find the defendant guilty of this charge, the state must prove the following elements

beyond a reasonable doubt:

Element 1 - Sold/gave/transferred personal identifying information

The first element is that the defendant (sold / gave / transferred) personal identifying information

to another person. “Personal identifying information” means:

(A) Any information that can be used, alone or in conjunction with any other information, to

identify or trace a specific individual including, but not limited to such individual’s name,

prior legal name, alias, date of birth, place of birth, mother’s maiden name, address,

telephone number, motor vehicle operator’s license number, Social Security number,

employee identification number, employer or taxpayer identification number, alien

registration number, government passport number, health insurance identification

number, demand deposit account number, savings account number, credit card number,

debit card number or unique biometric data such as fingerprint, voice print, retina or iris

image, or other unique physical representation;

(B) Any information that is linked or linkable to an individual, such as medical, financial,

educational, consumer, or employment information, data or records; or

(C) Any other sensitive private information that is linked or linkable to a specific identifiable

individual, such as gender identity, sexual orientation or any sexually intimate visual

depiction.

Element 2 - Not authorized

The second element is that the defendant knew that the information had been obtained without

the authorization of the person whose identifying information it was. A person acts “knowingly”

with respect to conduct or circumstances when (he/she) is aware that (his/her) conduct is of such

nature or that such circumstances exist. <See Knowledge, Instruction 2.3-3.>

Element 3 - For unlawful purpose

The third element is that the defendant knew that the third person intended to use the information

for an unlawful purpose. An unlawful purpose is anything that is prohibited by law. <Insert

specific allegations.>

Conclusion

In summary, the state must prove beyond a reasonable doubt that the defendant 1) (sold / gave /

transferred) personal identifying information to another person, 2) (he/she) knew that the

identifying information had been obtained without authorization, and 3) (he/she) knew that the

person to whom the information was transferred intended to use it for unlawful purposes.

If you unanimously find that the state has proved beyond a reasonable doubt each of the elements

of the crime of trafficking in personal identifying information, then you shall find the defendant

guilty. On the other hand, if you unanimously find that the state has failed to prove beyond a

reasonable doubt any of the elements, you shall then find the defendant not guilty.