The jury found 450 Stored Communications Act violations but awarded no actual or punitive damages. The Eleventh Circuit held that the Act does not permit statutory damages without actual damages, so it vacated the district court’s statutory-damages award of fifty thousand dollars; it also affirmed the denial of punitive damages and attorney’s fees. The court rejected Burkett’s challenges to the SCA verdict, jury instructions, evidentiary rulings, and denial of judgment as a matter of law. Judge Fay specially concurred: he agreed the award of fifty thousand dollars should be reversed, but would have remanded with instructions to reinstate the jury’s zero-damages verdict. The judgment was affirmed in part and vacated in part.