Plus the website for signup4cash.com has a nice like to reflected as a "business partner"...
It all goes together nicely.
The actually WHOLE complaint:
http://ftc.gov/os/caselist/0423168/0...omp0423168.pdf
In my opinion, the key to this situation is that the program owner / network owner / affiliate / employees all appear to be aware of the mailings, have paid for (an initiating act) for these mailings, and have rewarded the mailers for their actions. This isn't just a program accepting spam by accident, it would appear that the program's intentions from the word go are to work from spam traffic (as many programs have done in the past, I will add).
This is significantly different from a large affiliate program that might time to time have someone spamming their sponsor codes. A program that spots and takes timely action to stop accepting traffic and stop paying for it will probably not face legal issues any more than an ISP would if they take action to curtain the spam in a timely manner.
It's all about taking the appropriate actions. I hope that programs will learn to not only cancel the affiliate account, but to DECLINE THE TRAFFIC AS WELL.
Redirect spam traffic to google or something. Stop profiting from the actions that are clearly NOT going to be tolerated by the feds.
Alex