Appellate courts around the country are attempting to craft procedures that apply to the use of technology by cybercrime offenders once they leave incarceration. Disparate determinations are being made in regard to such offenders, allowing some to return to regular use of the Internet and e-mail, while others, such as notorious hacker Kevin Mitnick, was subjected to strict limitations on his access to computer systems during his three years of probation after release from prison.