There's an article on Techdirt about how a spammer was convicted for violating Virgina's Anti-Spamming Law. Jeremy Jaynes, the spammer in question, tried to get the conviction overturned because their anti-spam law is unconstitutional. The Virginia Supreme Court upheld the verdict.

While spam could be argued as free speech, even free speech has it's limits. You can't yell FIRE in a crowded theatre, and you can't come into my house and spew your hate speech.

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