can also be vulnerable to chargeware, which manipulates users into illegitimate mobile charges. Identity theft and fraud In one case, spyware has been closely associated with identity theft. In August 2005, researchers from security software firm Sunbelt Software suspected the creators of the common CoolWebSearch spyware had used it to transmit "chat sessions, user names, passwords, bank information, etc."; however it turned out that "it actually (was) its own sophisticated criminal little trojan that's independent of CWS." This case is currently under investigation by the FBI. The Federal Trade Commission estimates that 27.3 million Americans have been victims of identity theft, and that financial losses from identity theft totaled nearly $48 billion for businesses and financial institutions and at least $5 billion in out-of-pocket expenses for individuals. Digital rights management Some copy-protection technologies have borrowed from spyware. In 2005, Sony BMG Music Entertainment was found to be using rootkits in its XCP digital rights management technology Like spyware, not only was it difficult to detect and uninstall, it was so poorly written that most efforts to remove it could have rendered computers unable to function. Texas Attorney General Greg Abbott filed suit, and three separate class-action suits were filed. Sony BMG later provided a workaround on its website to help users remove it. Beginning on April 25, 2006, Microsoft's Windows Genuine Advantage Notifications application was installed on most Windows PCs as a "critical security update". While the main purpose of this deliberately uninstallable application is to ensure the copy of Windows on the machine was lawfully purchased and installed, it also installs software that has been accused of "phoning home" on a daily basis, like spyware. It can be removed with the RemoveWGA tool. Personal relationships Stalkerware is spyware that has been used to monitor electronic activities of partners in intimate relationships. At least one software package, Loverspy, was specifically marketed for this purpose. Depending on local laws regarding communal/marital property, observing a partner's online activity without their consent may be illegal; the author of Loverspy and several users of the product were indicted in California in 2005 on charges of wiretapping and various computer crimes. Browser cookies Anti-spyware programs often report Web advertisers' HTTP cookies, the small text files that track browsing activity, as spyware. While they are not always inherently malicious, many users object to third parties using space on their personal computers for their business purposes, and