One area I have seen this used are the 'spamvertized domains' in the body of
the message which would require a SURBL style test on the URL in the message
body.  Message headers, delivery, and MAILFROM are otherwise as valid as any
other spam; sometimes quite authentic.

----- Original Message ----- 
> The problem, though, is that any anti-spam program that does RHSBL tests
> probably does MAILFROM tests as well.  So while the domain won't be listed
> in any RHSBLs yet, it will fail the MAILFROM test, which is likely to be
> weighted higher.

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