Washington is considering a bill that would specifically grant jurisdiction to Washington Courts over non-resident, defendant spammers.
The Senate Committee Summary of the Bill:
"It is clarified that the district courts in Washington State have jurisdiction over actions brought against senders of spam in violation of Washington's anti-spam law. It is also clarified that it is proper for the district courts in Washington to hear actions against non-resident defendants who violate Washington's anti-spam law."
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