the delivery of all email to AOL members, forcing AOL to temporarily stop accepting any new messages. As the spam problem grew worse, AOL had to purchase millions of dollars worth of additional equipment to increase the capacity of its servers to handle the volume of email. The court held that this activity constituted a trespass to chattels and awarded injunctive relief, reasonable attorneys' fees and costs, as well as damages. Beyond spam: screen scraping and data harvesting Since the early spam cases, courts have extended the electronic trespass to chattels theory even further to encompass screen-scraping and other data "harvesting." Screen-scraping is the practice of taking information from another website, generally through the use of search agent software, and "harvesting" the data for one's own commercial use. For example, travel websites frequently use this tactic to offer a host of options and prices gleaned from various airlines' sites. Because the courts have entertained such litigation, some companies have specifically banned the conduct in their terms and conditions statements. In eBay v. Bidder's Edge (2000), eBay successfully used the trespass to chattels tort to prevent Bidder's Edge from employing spiders to cull information about its auctions to display on its own website. Although Bidder's Edge's robots only consumed a small percentage of eBay's computer resources, the court noted that the plaintiff need not demonstrate current substantial interference as conduct which constituted a use of another's property is enough to sustain a trespass to chattels claim. In light of this, the court found that eBay had demonstrated a sufficient likelihood of future injury to warrant granting a permanent injunction: "If the court were to hold otherwise, it would likely encourage other auction aggregators to crawl the eBay site, potentially to the point of denying effective access to eBay's customers." Register.com, Inc. v. Verio, Inc. (2000) is a further example of this temporary trend in which plaintiffs did not have to demonstrate any real interference. Register.com, a domain name registry service, sued competitor Verio for using Register.com's proprietary WHOIS look-up service to find potential leads among its customer base. The court found that, by continuing to access Register.com's online customer database after being told to stop, Verio was trespassing on Register.com's WHOIS server. Register.com had specifically withdrawn its consent to Verio's use of search robots to review Register.com's customer list. The court held that Verio caused harm to Register.com's files through the