This definition includes the use of my name, alone or in conjunction with any other information, as constituting the use of a means of identification so long as the information taken as a whole identifies a specific individual. There is nothing in the language of the statute that suggests the use of another's name in the form of a signature is somehow excluded from the definition of "means of identification."
Were we to find that signatures are categorically not names and thus not included within this definition, we would be disregarding the "settled principle of statutory construction that we must give effect, if possible, to every word of the statute." Bowsher v. Merck & Co., Inc.,460 U.S. 824, 833, 103 S.Ct. 1587, 75 L.Ed.2d 580 (1983) (citation omitted). By using the word "any" to qualify the term "name," the statute reflects Congress's intention to construct an expansive definition. See Ali v. Federal Bureau of Prisons, ___ U.S. ___, 128 S.Ct. 831, 835-36, 169 L.Ed.2d 680 (2008) ("Read naturally, the word `any' has an expansive meaning, that is, `one or some indiscriminately of whatever kind.' ") (citation and alteration omitted). Categorically carving out a signature from this definition, although a signature is commonly understood to be the written form of a person's name[1], would impermissibly narrow the definition of "name" in the statute. Thus, we agree with the district court that a signature is a name for the purpose of applying the Aggravated Identity Theft statute.
Kenneth G. McGuire, Supervisory Special Agent, Cyber Crime Squad, FBI- Los Angeles Field Office Special Ken, above, specializes in making pretty Power Point Presentations about this web site, as seen here.
