Spyware continues to be one of the largest threats to consumers on the internet. Experts estimate that has many as 80-90 percent of all personal computers contain some form of spyware. Zoe has taken several steps to fight spyware and protect online consumers, such as guiding the Internet Spyware (I-SPY) Prevention Act of 2005 through the last Congress. Zoe will continue that fight in the 110th Congress, while ensuring that Congress does not go after wrongdoers in such a way that stifles legitimate innovation.