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There were ways around the charges, like sending the spam messages from the Internet rather than a mobile phone.

Text spam used to be rare in the United States because, compared with the email equivalent, sending texts was expensive.

The past three years, however, have brought a proliferation of cheap, prepaid cellphone plans with unlimited text messaging. In 2009, Americans received some 2.2 billion text messages that they identified as spam, by the estimate of Richi Jennings, an independent market analyst. But even that figure doesn’t capture the biggest boom, which has come in just the past few months, according to Cloudmark, a San Francisco-based firm that provides messaging security for major wireless carriers.

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