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Spam is the subject of a number of state laws that form a different kind of “spam filter”. In September 2003, legislation was approved in California that made it the second state (after Delaware) to adopt an opt-in rule for e-mail advertising. Under this legislation, it is illegal to send unsolicited commercial e-mail from California or to a California e-mail address. The law applies to senders as well as to advertisers on whose behalf messages are sent. It also includes less restrictive rules from which the broad prohibition may be severed in the event that it is struck down as unconstitutional.