of $2.1 billion. In a 2009 opinion, Gordon v. Virtumundo, Inc., 575 F.3d 1040, the Ninth Circuit assessed the standing requirements necessary for a private plaintiff to bring a civil cause of action against spam senders under the CAN-SPAM Act of 2003, as well as the scope of the CAN-SPAM Act's federal preemption clause. United Kingdom In the first successful case of its kind, Nigel Roberts from the Channel Islands won £270 against Media Logistics UK who sent junk e-mails to his personal account. In January 2007, a Sheriff Court in Scotland awarded Mr. Gordon Dick £750 (the then maximum sum that could be awarded in a Small Claim action) plus expenses of £618.66, a total of £1368.66 against Transcom Internet Services Ltd. for breaching anti-spam laws. Transcom had been legally represented at earlier hearings, but were not represented at the proof, so Gordon Dick got his decree by default. It is the largest amount awarded in compensation in the United Kingdom since Roberts v Media Logistics case in 2005. Despite the statutory tort that is created by the Regulations implementing the EC Directive, few other people have followed their example. As the Courts engage in active case management, such cases would probably now be expected to be settled by mediation and payment of nominal damages. New Zealand In October 2008, an international internet spam operation run from New Zealand was cited by American authorities as one of the world's largest, and for a time responsible for up to a third of all unwanted e-mails. In a statement the US Federal Trade Commission (FTC) named Christchurch's Lance Atkinson as one of the principals of the operation. New Zealand's Internal Affairs announced it had lodged a $200,000 claim in the High Court against Atkinson and his brother Shane Atkinson and courier Roland Smits, after raids in Christchurch. This marked the first prosecution since the Unsolicited Electronic Messages Act (UEMA) was passed in September 2007. The FTC said it had received more than three million complaints about spam messages connected to this operation, and estimated that it may be responsible for sending billions of illegal spam messages. The US District Court froze the defendants’ assets to preserve them for consumer redress pending trial. U.S. co-defendant Jody Smith forfeited more than $800,000 and faces up to five years in prison for charges to which he pleaded guilty. Bulgaria While most countries either outlaw