LOA is an Internet service provider located in Virginia. Freeman is the creator and operator of defendants AAF Marketing and AAF Industries (collectively AAF). LOA alleges that Freeman and AAF improperly sent unauthorized bulk e-mail advertisements (“spam”) to LOA subscribers. Specifically, LOA alleges that Freeman sent over 60 million e-mail messages over the course of 10 months, many of which contained the letters “loa.com” in their headers; that he continued to send unauthorized bulk e-mail after he was notified in writing by LOA to cease and desist these activities; that his activities caused LOA to spend technical resources and staff time to “defend” its computer system and its membership against this spam; and that Freeman’s messages damaged LOA’s goodwill among its members and generated more than 50,000 member complaints. Discuss whether LOA will prevail in an action against AAF.