The following excerpt is from U.S. v. Williams, 441 F.3d 716 (9th Cir. 2006):
The "intangible rights" theory has been a subject of controversy in the history of the federal mail and wire fraud statutes. Before 1987, this circuit, among others, interpreted 1341 and 1343 to proscribe two categories of fraudulent "schemes." United States v. Bohonus, 628 F.2d 1167, 1171 (9th Cir.1980). The first included schemes to deprive others of tangible property interests, and the second included schemes to deprive others of intangible rights. Id.
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