The US Federal Trade Commission, acting under the authority of the CAN-SPAM Act, ruled earlier this year that sexually explicit emails must contain the words SEXUALLY EXPLICIT in the subject line.

Microsoft calls it the brown paper wrapper rule, named after regulations on displaying adult material in shops. The latest enforcement actions are among the first that invoke that particular part of CAN-SPAM.

Microsoft says is has filed 86 suits against alleged spammers in the US to date and is committed to filing lawsuits against spammers and other cybercriminals until the problems of spam and other cybercrime have abated substantially.