I think its no possible to filter mails bye its whois entry. you can only filter some text that it be in the message or in the header from the mail. if you want to do that you must write a litte separete progam that make for all incomming mail a whois lookup and i thing that's not a good idea. i think it must be another way to catch this spam mails. (ipaddresss or else)
That's sorta what David Funk was suggesting. "eval" rules run a Perl fragment to analyze the message for some pattern, which might include some kind of network database transaction like DNS or whois. One of the coming features in SA is the ability to add custom eval rules. Check bugzilla traffic over the last month or so for discussion about this.
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