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However, as email marketing developed as an effective means of direct communication, in the 1990s, users increasingly began referring to it as "spam", and began blocking out content from emails with filters and blocking programs. In order to effectively communicate a message through email, marketers had to develop a way of pushing content through to the end user, without being cut out by automatic filters and spam removing software.
The Australian Spam Act 2003 is enforced by the Australian Communications and Media Authority, widely known as "ACMA". The act defines the term unsolicited electronic messages, states how unsubscribe functions must work for commercial messages, and gives other key information. Fines range with 3 fines of AU$110,000 being issued to Virgin Blue Airlines (2011), Tiger Airways Holdings Limited (2012) and Cellar master Wines Pty Limited (2013).