A recent decision in the Western District of Washington broadly defines the reach of the private right of action under the federal CAN-SPAM statute. In that case, Haselton v. Quicken Loans Inc., W.D. Wash., C-07-1777, 10/14/08, the court held that a company had standing to sue alleged spammers even though it is not an Internet service provider (ISP) and does not provide e-mail accounts to its customers.