Historical perspective: In September, 2009 Microsoft filed five state civil lawsuits against suspected fraudsters in what the software giant claims are the first-ever legal moves against this activity. The suits come on th heels of an attack on the
New York Times'
Web site, where what was purported to be a Vonage ad turned out to be malware that served readers fake warnings that their computers were infected, along with a link to buy "antivirus software" to clean them up. This type of rougeware (see warez) is efficient and lucrative, with 374,000 new versions of rougeware appearing in the second quarter of 2009 alone.