United States v. Cyberheat, Inc., No. CV-05-457-TUC-DCB, 2007 U.S. Dist. LEXIS 15448, 2007 WL 686678 (D. Ariz. Mar. 2, 2007)

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You can protect your computer from viruses without expensive software. Instead, follow these simple tips:

Stay up-to-date on all system updates.

Don't download any email attachments you weren't expecting.

Avoid freeware and peer-to-peer sharing sites.

Use alternative web browsers and email software.