N.C.P.I.—Crim. 223.30

The defendant has been charged with willfully damaging

[computers] [computer programs] [computer systems] [computer

networks].

For you to find the defendant guilty of this offense, the State must

prove three things beyond a reasonable doubt:

First, that the defendant willfully [altered] [damaged] [destroyed] a

[computer] [computer program] [computer system] [computer network]

(or any part thereof).1

Second, that the defendant acted without authorization.

And Third, that the damage caused by the [alteration] [damage]

[destruction] was in excess of one thousand dollars ($1,000).

If you find from the evidence beyond a reasonable doubt that on or

about the alleged date, the defendant willfully and without authorization

[altered] [damaged] [destroyed] a [computer] [computer program]

[computer system] [computer network] (or any part thereof) and that the

damage caused by the [alteration] [damage] [destruction] was in excess

of one thousand dollars ($1,000), it would be your duty to return a verdict

of guilty of felonious damage to computers. If you do not so find or have

a reasonable doubt as to one or more of these things, you would not

return a verdict of guilty but would determine whether the defendant is

guilty of non-felonious damage to computers, which differs from the

felony in that the State need not prove that the damage caused was in

excess of one thousand dollars ($1,000).

If you find from the evidence beyond a reasonable doubt that on or

about the alleged date, the defendant willfully and without authorization

[altered] [damaged] [destroyed] a [computer] [computer program]

[computer system] [computer network] (or any part thereof), it would be

your duty to return a verdict of guilty. If you do not so find or have a

reasonable doubt as to one or more of these things, it would be your duty

to return a verdict of not guilty.