California won its first anti-spam judgement when a court fined a marketing firm $US2 million ($A2.87 million) for sending out millions of unsolicited emails telling people how to spam, the state's attorney general said.

Attorney General Bill Lockyer brought the case against PW Marketing of Los Angeles County and its owners Paul Willis and Claudia Griffin in 2002 under a 1998 state anti-spam law. The law was strengthened last month to make it easier to sue spammers.

Lockyer's spokesman Tom Dressler said on Friday that while this case was decided under the original statute, the attorney general's office expects in the future it will be easier to try cases under the updated, tougher law.

PW Marketing and Willis and Griffin were charged with sending out millions of e-mails advertising ``how to'' guides on spamming and long lists of email addresses.

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