available for access by [the vendor defendants] and non-party Ascent.”). Plaintiffs have failed to state a direct cause of action based on unauthorized access. Second, because plaintiffs clarified at oral argument that they are not asserting § 2701-based liability against American, the vendor defendants cannot be held liable under § 2701 as aiders and abettors or conspirators of American. Third, even if plaintiffs’ clarification means that they intend to hold the vendor defendants liable as aiders and abettors of or coconspirators with AAI, because the court is dismissing plaintiffs’ § 2701-based claim against AAI, it follows that the vendor defendants cannot be held liable as aiders and abettors or coconspirators. See In re Managed Care Litig., 298 F.Supp.2d 1259, 1286 (S.D.Fla.2003) (<HOLDING>); Coppock v. Northrop Grumman Corp., 2003 WL
holding that civil liability for aiding and abetting requires showing that substantive offense was committed recognizing aiding and abetting trespass recognizing aiding and abetting conversion recognizing both aiding and abetting breach of fiduciary duties and aiding and abetting conversion holding it was not a surprise or unfair to the defendant for the state to pursue a theory of aiding and abetting at trial when the charging document did not refer to aiding and abetting