The Future of Spam Litigation After Omega World Travel V. Mummagraphics‪.‬

I. INTRODUCTION Unsolicited commercial e-mail ("UCE"), commonly known as spam, (1) is both ubiquitous and profitable. (2) In 2006, approximately forty percent of the thirty-one billion e-mails sent daily were classifiable as spam, costing U.S. corporations an estimated $8.9 billion and non-corporate Internet users $255 million. (3) While many delete these messages, UCE does convince some recipients to buy the advertised products, and the combination of sizeable audience and low cost to the advertiser makes this medium highly profitable. (4) The real costs of UCE are borne by recipients in the form of lost time and by Internet Service Providers ("ISPs") in the form of higher operating expenditures. (5)