Second, participants of cooperation in E-mail supervision and external enforcement are mainly developed countries who take up a very small amount of the net-covered countries, for example, there are only less than thirty countries （regions） involved in the London Action Plan till present, which probably enjoys the broadest participants.[29]

　　Third, the current international cooperation is limited to enforcement collaboration of implementation agencies leaving blank of legislative and criminal juridical cooperation, etc. at present, cooperation mainly involves two parts. The first part is information exchange, which includes legislative information, policy information and technical information exchange, notification of anti-spam action for example. The other part of cooperation is assistance of investigation and obtaining evidence in the territory of a contracting party for the sake of facilitating anti-spam enforcement action of another participant. There is no international cooperation in juridical assistance and legislative coordination on E-mail, which should include the unification of existing E-mail legislations and urging the relevant countries on making spam supervision regulations.

　　3. The Determinants of Legal Structure of International E-mail Regulation

　　Strictly speaking, there is no international law within contemporary order or system of international regulation of E-mail. Then, the next question is what factors contribute to the system. The following will show that there are two factors related to the system of international spam regulation. One reason is that the differences of values, policies and laws on the control of E-mails are big, and the cross-country coordination of nation interests is difficult; another reason is that the regulation and control of E-mails is a complex and small issue, and it is difficult for the international law to emerge in the field.

　　3.1. The differences of legislation relating to anti-spam among countries are big

　　We can demonstrate the legal differences related with anti-spam from three perspectives: （a） whether one country has the legislation related with E-mails, （b） the difference in the regulation approach and the specific contents of the legislation in the countries which have the legislation about anti-spam, and （c） the difference in the legal liability against spam.

　　First, most of the countries or areas in the world do not make laws against spam.

　　Only a few countries or areas have legislations against spam in the world currently. The website of ITU has updated the survey of the domestic legislation about anti-spam. According to the information collected and surveyed by ITU, there are about twenty eight countries or areas that have the legislations in the field of E-mail regulation worldwide. They are Argentina, Canada, Chile, China, Columbia, Denmark，Estonia, European Union, Finland, France, Iceland, Italy, Japan, South Korea, Hong Kong, Lithuania, Malta, Mexico, New Zealand, Portugal, Russia, Singapore, Spain, Swiss, United Kingdom, and United States. Thus, most of the countries （and areas） do not have the legislation against spam. That’s to say, the behavior of sending E-mails, no matter sending the unsolicited bulk E-mails in order to market or other bulk information, is the sphere of the freedom of citizens, and legal. So it is difficult for these countries where sending E-mails are free, to become a party of the multilateral framework or convention against spam.

　　Second, the legal approach to the E-mail governance is not the same.

　　It’s different in the logic of legislation on how to regulate the E-mails and govern the internet even though in the countries with the anti-spam legislation. The United States and Australia may be the earliest ones with law and regulation against spam, but they believe in different philosophy of regulation and adopt different legal approach respectively. The U. S. is fairly typical of the countries that choose the regulation approach of opt-out. The countries such as the Australia adopt the one of opt-in. The anti-spam approach of opt-out is different from the one of opt-in.

　　Generally speaking, the legal approach of opt-out means that only if the receivers choose not to be put in the list of the senders or give senders a notice that the receivers hope not to receive the E-mails from the E-mail address, it is illegal for the senders to continue to send the unsolicited E-mails to the recipients. That means sending E-mails is the sphere of speech freedom and legitimate commercial freedom, and each senders at least have one chance to send a marketing E-mail to each E-mail addresses. [30]

　　On the other hand, others adopt another different logic and approach to regulate E-mails. For instance, the anti-spam legislation of Australia may be the most advanced ones in the world. It forbids all the E-mails without the consent or permission of the recipients. “Consent” includes the express consent and the non-express consent of the recipients, to which the judgers can reach only by the objective and extrinsic situations. [31]