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THE INCREASING PREVALENCE OF SPYWARE “Spyware appears to be a new and rapidly growing practice that poses a risk of serious harm to consumers” Spyware includes “[a]ny software that covertly gathers user information through the user’s Internet connection without his or her knowledge, usually for advertising purposes” [20]. The definition is so broad that it may cover software that is beneficial and benign, or software that has poorly written, inefficient code . The Center for Democracy and 738 Technology, a policy research group, has proposed that software which hijacks web traffic, tracks internet users without their knowledge and consent, and is not easily removable should be considered spyware. As presented in Table 1, an audit of over 4.6 million PCs to date found 116.5 million instances of spyware, averaging 25 per PC [17]. Over 7,000 spyware programs are estimated to be running on millions of corporate and personal computers