Last month, in Asis Internet Services, et al., v. Subscriberbase, Inc., et al., a federal district court in California held that the CAN-SPAM Act does not preempt a claim under a California spam law even though such a claim does not require proof of all the elements of a common law fraud claim. The court held, however, that this claim still must be pleaded with particularity, and that this means that plaintiffs must say something about the specifics of every email that they allege violated the California statute.