In fact, at least one analyst said the San Jose, Calif., court's decision could acually make it harder for sites like .

"I fear the major consequence from the fine will, unfortunately, be to spur social network spammers to become more sophisticated," said Dan Olds, principal analyst with Gabriel Consulting Group. "You'll see them covering their tracks better, making sure they are in jurisdictions that make it hard for legal authorities to reach them, and making their mechanisms more insidious and hard to stop."

Olds' speculation comes a day after Judge Jeremy Fogel ordered to pay Facebook $711 million in damages for flooding the social network with spam messages starting around November 2008. Facebook noted on its Web site Thursday that Wallace, dubbed the Spam King, accessed people's accounts without their permission and sent phony Wall posts and messages .

Facebook also said that Judge Fogel referred the case to to the U.S. Attorney's Office with a request that Wallace be prosecuted for criminal contempt.

"While we don't expect to receive the vast majority of the award, we hope that this will act as a continued deterrent against these criminals," Sam O'Rourke, a member of Facebook's legal team, wrote in a .