As I mentioned previously, we would say the private right of action should be targeted toward the companies that bear the costs of spam and allow them to partner with CRTC in enforcement.
Often the networks' email providers can tell you who the bad spammers are. They are the ones in the best location to often find them, and so if the private right of action were changed to allow them to partner with CRTC, to themselves go after and recoup the costs from the spam on their own networks, that could help everyone and help the law be more successful.