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An estimated 9 out of 10 HTML emails are not W3C HTML compliant, which can cause rendering as well as delivery issues, particularly at MSN and Hotmail. One of the dirtiest tricks in a spammer's arsenal is invalid, broken, and malicious HTML code, used to obfuscate their payload. If you "do it yourself" and use HTML in your messages, make sure your code is error-free and follows W3C HTML guidelines - or try a service that enforces W3C HTML guidelines automatically.