"Last year's U.S. effort to criminalize spam has been so unsuccessful junk e-mail has actually increased since Congress passed the CAN-SPAM Act. Since the measure took effect in January 2004, unsolicited junk e-mail on the Internet has come to total perhaps 80 percent or more of all e-mail sent, up from 50 percent to 60 percent of all e-mail before the law went into effect."