Harm to the marketplace. When a spammer sends an e-mail message to a million people, it is carried by numerous other systems en route to its destinations, once again shifting cost away from the originator. The carriers in between suddenly are bearing the burden of carrying advertisements for the spammer. The number of unsolicited messages sent out each day is truly remarkable. Spam-filtering company Bright Light Technologies claims its research shows more than 25 million unsolicited messages are sent every day. Numerous court cases are under way between spammers and the innocent victims who have been subjected to such floods. Unfortunately, whereas major corporations can afford to fight these cutting-edge cyberlaw battles, small mom-and-pop ISPs and their customers are left to suffer the floods.