In Carpenter v. United States, 484 U.S. 19, 108 S.Ct. 316, 320-21, 98 L.Ed.2d 275 (1987) the Court clarified McNally by pointing out that property rights can be intangible--like a newspaper's right to exclusive use of the information it uncovers--as well as tangible and that the fraud statutes protect both kinds of property (interpreting an identically worded provision in the wire fraud statute, 18 U.S.C. Sec. 1343). Carpenter, however, reiterated that non-property rights are not covered by the mail and wire fraud statutes: "The Journal, as Winan's employer, was defrauded of much more than its contractual right to his honest and faithful service, an interest too ethereal in itself to fall within the protection of the mail fraud statute ..." Id., 108 S.Ct. at 320.