entities that do business with spammers would dramatically reduce monetization of unwanted e-mails. Moreover, this blacklist could be updated far more rapidly than spammers could acquire new banking resources, an asymmetry favoring anti-spam efforts. Political issues An ongoing concern expressed by parties such as the Electronic Frontier Foundation and the American Civil Liberties Union has to do with so-called "stealth blocking", a term for ISPs employing aggressive spam blocking without their users' knowledge. These groups' concern is that ISPs or technicians seeking to reduce spam-related costs may select tools that (either through error or design) also block non-spam e-mail from sites seen as "spam-friendly". Few object to the existence of these tools; it is their use in filtering the mail of users who are not informed of their use that draws fire. Even though it is possible in some jurisdictions to treat some spam as unlawful merely by applying existing laws against trespass and conversion, some laws specifically targeting spam have been proposed. In 2004, United States passed the CAN-SPAM Act of 2003 that provided ISPs with tools to combat spam. This act allowed Yahoo! to successfully sue Eric Head who settled the lawsuit for several thousand U.S. dollars in June 2004. But the law is criticized by many for not being effective enough. Indeed, the law was supported by some spammers and organizations that support spamming, and opposed by many in the anti-spam community. Court cases United States Earthlink won a $25 million judgment against one of the most notorious and active "spammers" Khan C. Smith in 2001 for his role in founding the modern spam industry which dealt billions in economic damage and established thousands of spammers into the industry. His email efforts were said to make up more than a third of all Internet email being sent from 1999 until 2002. Sanford Wallace and Cyber Promotions were the target of a string of lawsuits, many of which were settled out of court, up through a 1998 Earthlink settlement that put Cyber Promotions out of business. Attorney Laurence Canter was disbarred by the Tennessee Supreme Court in 1997 for sending prodigious amounts of spam advertising his immigration law practice. In 2005, Jason Smathers, a former America Online employee, pleaded guilty to charges of violating the CAN-SPAM Act. In 2003, he sold a list of approximately 93 million AOL subscriber e-mail addresses to Sean Dunaway who sold the list