Congress first addressed the issue of junk faxes in the Telephone Consumer Protection Act of 1991 (TCPA). Although this legislation dealt broadly with larger issues of nuisance telemarketing tactics, it included provisions making it illegal for any person to send an unsolicited advertisement to a fax machine. The law further authorized the recipient of a fax sent in violation of the statute (or a regulation promulgated under the statute) to sue the sender in state court to enjoin further violation, recover for actual monetary losses from such a violation, $500 in statutory damages for each violation (whichever is greater), or both. The law also allows the court, in its discretion, to treble these damages if it finds the defendant violated the statute "willfully" or "knowingly."