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(71.) See Marcus, supra note 8, at 254 ("America Online is not really suing Cyber Promotions for spamming.
Merle's Cyber Promotions has launched a new web site designed to help small businesses achieve better visibility on the Internet.
Instead, we'd be left with companies like Cyber Promotions, and we can more easily deal with them by cutting off their Net access or simply refusing to accept any mail whatsoever from any site known to transmit their mail.
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