for credit and even though the company stated that the essays they wrote were for research purposes only, their advertising scheme encouraged otherwise by boasting about grades. The court determined that the disclaimers did not sufficiently protect the company because their encouragement of cheating and plagiarism hurt the educational system. The ruling called for the company to cease business in the State of New York. Several other legal battles have been fought since and have largely resulted in the punishment of the term paper writers rather than the students purchasing them. California Education Code Section 66400 "penalizes the preparation or sale of term papers, theses, or dissertations for compensation ...." The law is applicable when the preparer/seller knew or should have known that the recipient would submit the paper for academic credit. State residents or academic institutions "acting for the interest of itself, its students, or the general public" can file suit against offenders for "any relief as is necessary." This law differs from that of New York in various ways, including holding the vendor responsible even if it claims that the paper was not intended to be turned in for credit, if the court concludes that it should have known that it would, or if the claim is not credible. For example, while some essay mills state that their products are not intended to be submitted for credit, they may also boast of the high grades that their papers have received. The 2011 Florida Statutes Section 877.17 states that it is a second degree misdemeanor to "sell, offer to sell, or advertise for sale" a "written, recorded, pictorial, artistic, or other assignment" to another for submission "unaltered to a substantial degree." In the state of Florida, second degree misdemeanors are punishable by up to sixty days in prison. Criticism and controversy The academic community has criticized essay mill companies for helping students to commit academic fraud. Some essay mills have defended themselves against criticism by claiming that they are selling pre-written examples which students can use as guidelines and models for the student's own work. In 2002, a UK-based essay mill called Elizabeth Hall Associates required students purchasing essays to sign a disclaimer stating that "any material provided by Elizabeth Hall Associates [is] on the understanding that it is a guidance model only." Other essay mills claim that they are "scholarly publishing houses" that provide students with essays that