Verizon wins injunction against text message spammers.

Reuters reports that Verizon Wireless has obtained an injunction against Passport Holidays of Ormond Beach, FL after 98,000 spam text messages were sent on its behalf. Passport will also pay $10,000 in damages.

My only questions are how did it go so far in the first place, and why doesn't this fall under USC title 47 which would have allowed $500/message in damages?