In United States v. Smith, the Eleventh Circuit vacated one theft-of trade-secrets conviction and the related sentencing enhancements due to improper venue and affirmed and remanded for resentencing a second related conviction. A jury in the District Court for the Northern District of Florida convicted Timothy J. Smith of one count of theft of trade secrets and one count of extortion. On appeal, the Eleventh Circuit held that the venue was improper as to Smith’s conviction of theft of trade secrets because he committed no “essential conduct in that location,” and therefore the conviction was vacated. The court also found sufficient evidence to affirm Smith's conviction of extortion, and because vacation of the first count did not necessitate the vacation of another, the court remanded the case for resentencing.