> > Does it make sense to track how many valid & invalid addresses are
> > provided for a message, and allow a threshold to consider that spam?

> Hmm we could do so and reject such a message after the data.
> any other thoughts ?

Well, according to RFC 2821, 354 is not the only valid reply code to DATA:

   DATA
      I: 354 -> data -> S: 250
                        E: 552, 554, 451, 452
      E: 451, 554, 503

503 would be wrong, and I consider 451 (Requested action aborted due to a
local error) rather dubious, but 554 (Transaction failed) seems reasonable.

        --- Noel



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