In subsequent cases, the payment per class member has increased to $200 in 2011 and $500 in 2013.[6][7] In response to Satterfield, entities who make money sending mobile phone spam formed the Mobile Advocacy Coalition (MAC) to lobby the government to legalize that activity.[8] In the US, the Federal Trade Commission (FTC) has expanded Phone Spam regulations to cover also Voice Spam—mostly in form of prerecorded telemarketing calls—commonly known as robocalls;[9] victims can file a complaint with the FCC.[10] In California, Section 17538.41 of the B&P Code bans text message advertisement.[11] Consumers can sue on an individual or class basis per a private right of action against unfair business practices.[12] In 2019, senators John Thune, Roger Wicker and Ed Markey introduced a new proposal titled the Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACE) to deter criminal robocall violations and improve enforcement [13] which passed the Senate on May 22, 2019.[14]