Another kind of illegal access by minors is that which involves computer and Internet activities. In 2003, The Recording Industry Association sued 261 persons for downloading protected music onto their personal computers and infringing copyrights. Among the defendants were several surprised parents who had no knowledge of their minor child’s downloading activities. In Thrifty-Tel v. Bezenek, the California Court of Appeals upheld a verdict against the parents of juvenile computer hackers who accessed the phone company’s network in order to make long-distance calls without cost. And with the appearance of camera cell-phones and computer video cameras in the early 2000s, the opportunity for minors to sell pornographic images of themselves or otherwise engage in illegal Internet activities has increased dramatically. In such matters, federal law (e.g. Section 301 of the Copyright Act) may preempt state laws and provide a more uniform guidance for resolution. However, these examples point to the need for a more comprehensive approach to parental liability across state lines.