A September decision by a federal court may mean more spam hitting inboxes, an analyst said Wednesday.

Last month, the U.S. District Court for the Northern District of Illinois ruled in favor of e-mail marketing company e360insight, and ordered U.K.-based Spamhaus, a non-profit anti-spam organization, to pay $11.7 million in damages. e360insight had argued that the Spamhaus blacklist -- a database of spammers and suspected spammers that is widely used by spam filtering services and software -- erroneously included its domain. Spamhaus did not contest the case, but has refused to pay the fine, issue an apology, or remove e360insight from the blacklist.

The fear, said Richi Jennings, an analyst with messaging research company Ferris Research, is that the judge will next order ICANN (Internet Corporation For Assigned Names and Numbers), the U.S.-based organization which manages domain names, to strip Spamhaus of its domain in an attempt to force the company to comply.

"In the short term, any spam filter that relies on Spamhaus' blacklist will have a problem with its accuracy," said Jennings. "But I don't think it will come to that. Spamhaus will either find a way to make sure that U.S. law can't touch them, or some other group will step in to fill the hole."

Spamhaus itself has said the U.S. court has no jurisdiction, stands by its categorization of e360insight as a spammer, and remained defiant at the news of a possible domain stripping.

"We think it can not actually happen, due to the effect it would have both on the Internet and on millions of users," Spamhaus said in a statement posted on its Web site Tuesday.

Spamhaus claimed that its blacklist blocks 50 billion spam messages daily. "The effect of suddenly not blocking such a large amount of spam would mean that volume of unwanted junk hitting mail server queues all over the world. The effect of 650 million email boxes suddenly receiving a barrage of illegal spam, scams, and bank phishes is extremely dangerous. For this reason alone we believe that ICANN suspending spamhaus.org is almost certainly a no-starter."