United States Fourth Circuit

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Beyond Systems v. Kraft Foods, 13-2137

In this case, plaintiff internet service provider seeks statutory damages against defendants under California's and Maryland's anti-spam statutes on grounds that it received several hundred emails which it alleges were unlawful spam. Judgment of the district court entered in favor of defendants is affirmed, where: 1) plaintiff consented to and solicited the harm underpinning its anti-spam claims by intentionally participating in routing spam email between California and Maryland to increase its exposure to spam and thereby allow it to sue under both states' laws; and 2) plaintiff is therefore barred from recovery.

Appellate Information

  • Decided 02/04/2015
  • Published 02/04/2015


  • Wynn


  • United States Fourth Circuit


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