I just received this spam a little while ago.  What many novice users will find 
is a site identical to paypal.  The problem is the link actually goes to 
http://shelbycreative.com/alacarte/webscr.dll which emulates the paypal site 
exactly, pop's it up in a new window and asks you for all of your CC 
information.
 
I think it might be time to create a rule that says if the link domain 
(whatever.com) doesn't match the href domain (for at least two levels of the 
TLD) it should be considered spoof.
 
This might help out a lot.  Unfortunately I'm on outlook web access so I can't 
get all of the headers.
 
Gary Smith
  

Dear PayPal user,


 We recently reviewed your account, and suspect that your PayPal account may
 have been accessed by an unauthorized third party. Protecting the security
 of your account and of the PayPal network is our primary concern.
 Therefore, as a preventative measure, we have temporarily limited access to
 sensitive PayPal account features.
 Click below in order to regain access to your account:
 https://www.paypal.com/cgi-bin/webscr?cmd=_login-run 
<http://shelbycreative.com/alacarte/webscr.dll>   
 
 For more information about how to protect your account, please visit
 PayPal's Security Center, accessible via the "Security Center" link located
 at the bottom of each page of the PayPal website. 
 
 We apologize for any inconvenience this may cause, and appreciate your
 assistance in helping us maintain the integrity of the entire PayPal
 system. Thank you for your prompt attention to this matter.
 
 Sincerely,
 The PayPal Team
 
 
 Please do not reply to this e-mail. Mail sent to this address cannot be
 answered. For assistance, log in to your PayPal account and choose the
 "Help" link in the header of any page.
 
 
 PayPal Email ID PP198
 PayPal Email ID PP316


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