From this:

In one case, Microsoft accuses two Dayton, Ohio, companies, Email Gold and NetGold, and three individuals of sending repeated offers for a how-to spam kit to its members using falsified MSN and Hotmail domains. In another case, Microsoft alleges a Haddonfield, N.J., company, The E-Offer Store, sent spam using fake subject lines. Other cases involve either false subject lines or spoofed domain names. Two cases list the defendants as John Doe...