Doesn't look like it applies to SA, but interesting nonetheless.

http://www.theregister.co.uk/content/55/36666.html
http://patft.uspto.gov/netacgi/nph-Parser?Sect1=PTO1&Sect2=HITOFF&d=PALL&p=1&u=/netahtml/srchnum.htm&r=1&f=G&l=50&s1=6,650,890.WKU.&OS=PN/6,650,890&RS=PN/6,650,890

The start of the patent:

1. A method of providing electronic messaging services in an email network 
comprising a sending email server and a destination email server, wherein 
emails may be delivered from the sending email server to the destination 
email server via an electronic message delivery path through existing 
Internet infrastructure, the method comprising:

(a) inserting an intermediate pre-processing service into the electronic 
message delivery path by changing a Domain Name Server entry containing an IP 
address of the destination email server to contain an IP address of the 
intermediate pre-processing service;

(b) receiving in the intermediate pre-processing service email message data 
addressed to the destination email server that has been routed through the 
intermediate pre-processing service; and

(c) simultaneously with receiving the email message data in the intermediate 
pre-processing service, processing the e-mail message data and, if the 
processing of the email message data instructs delivery to the destination 
email server, delivering the email message data to that server. 

So 1(c) doesn't apply to SA, unless the sysadmin configures the server to 
quarentine spam rather than simply adding markup, and 1(a) doesn't apply if 
SA is integrated into the destination server, rather than an intermediate 
mail server.

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