Ill. Pattern Jury Instr. (Criminal) 13.50C

To sustain the charge of computer tampering, the State must prove the following

propositions:

First Proposition: That the defendant knowingly [(inserted) (attempted to insert)] a

program into a [(computer) (computer program)]; and

Second Proposition: That the defendant [(knew) (had reason to believe)] that the

program which he [(inserted) (attempted to insert)] contained information or commands that [

(would) (might)] [(damage that computer or any other computer subsequently accessing or

being accessed by that computer) (destroy that computer or any other computer subsequently

accessing or being accessed by that computer) (alter a computer program or data from that

computer or any other computer program or data in a computer subsequently accessing or being

accessed by that computer) (delete a computer program or data from that computer or any other

computer program or data in a computer subsequently accessing or being accessed by that

computer) (remove a computer program or data from that computer or any other computer

program or data in a computer subsequently accessing or being accessed by that computer)

(cause loss to the users of that computer or the users of a computer which accesses or which is

accessed by such program)]; and

Third Proposition: That the defendant acted [(without the authorization of the

computer's owner) (in excess of the authority granted to him by the computer's owner)]; and

Fourth Proposition: That the defendant knew that he acted [(without the authorization of

the computer's owner) (in excess of the authority granted to him by the computer's owner)].

If you find from your consideration of all the evidence that each one of these propositions

has been proved beyond a reasonable doubt, you should find the defendant guilty.

If you find from your consideration of all the evidence that any one of these propositions

has not been proved beyond a reasonable doubt, you should find the defendant not guilty.