N.C.P.I.—Crim. 226.72C

The defendant has been charged with the cyber-bullying of a school

employee.

For you to find the defendant1 guilty of this offense, the State must

prove five things beyond a reasonable doubt:

First, that the defendant used a [computer] [computer network];

Second, that the defendant [copied and disseminated] [caused to

be made] an unauthorized copy of any data2 pertaining to (name school

employee);

Third, that the defendant did this for the purpose of [intimidating]

[tormenting] that school employee;

Fourth, that the defendant was a student at (name school);

And Fifth, that the victim of the cyber-bullying was a school

employee.3

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

about the alleged date the defendant was a student and used a

[computer] [computer network], and that the defendant [copied and

disseminated] [caused to be made] an unauthorized copy of any data

pertaining to a school employee, and that the defendant did this for the

purpose of [intimidating] [tormenting] that school employee, 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, then it would be

your duty to return a verdict of not guilty.