International Foundation for Electoral Systems for either Members of the House or Senate,196 and although there is no minimum or maximum fine prescribed in the statute, there are also no cases on record where the criminal penalty has been utilized. Anyone may file a complaint with either the Franking Commission or the Select Committee on Ethics regarding suspected violations of the franking privilege.197 However, if an individual were to sue a Member for abuse of the franking privilege in federal court, standing and available remedies would be severely limited.198 Because legislation mandates that a complaint regarding abuse of the franking privilege is submitted to either the Select Committee on Ethics or the Franking Commission before a court will have jurisdiction to hear any civil action on the issue, there are few abuse of franking privilege cases brought in court that survive standing challenges.199 Courts that have heard cases despite this requirement have found that a candidate for Congress has standing to sue on the grounds that the abuse puts the incumbent at an unfair advantage,200 or that his or her right to run for office is violated by the abuse.201 However, even if a plaintiff were to survive a standing challenge, not only is injunctive relief the only available remedy,202 but the plaintiff must also prove that there is a likelihood of additional violations in the future and that the injunctive relief is proper to prevent an unfair advantage in the election.203 Thus, filing civil actions in courts is uncommon practice today.204 But the lack of civil actions may also be contributed to the fact that the Franking Commission must approve franked mass communication before it is sent out,205 and consequently, much of the illegal use of the franking privilege has been greatly reduced.206 18 U.S.C.A. § 1719 (“[w]hoever makes use of any official envelope, label, or indorsement authorized by law, to avoid the payment of postage or registry fee on his private letter, packet, package, or other matter in the mail, shall be fined under this title”). 197 See Jacob R. Straus, supra note 163, at 15; see also 2 U.S.C.A. § 501(e); The Commission on Congressional Mailing Standards, Regulations on the Use of the Congressional Frank By Members of the House of Representatives & Rules of Practice in Proceedings Before the House Commission on Congressional Mailing Standards 28 (2015). 198 See Barbara J. Van Arsdale et al., supra note 161, at § 63:73 (citing to Cervase v. Rangel, 464 F. Supp. 68 (S.D. N.Y. 1978) (holding that when the only injury plaintiff alleges due to the abuse of the franking privilege is tax liability, plaintiff will not have standing)). 199 See Leah Sellers, We Should Abolish the Franking Privilege, Mass Constituent Communications, and other Campaign-Related Government Speech But Frankly, It Won’t Be Easy, 42 U. Tol. L. Rev. 131, 145 (2010); see also 2 U.S.C.A § 501(e); 2 U.S.C.A. § 502(c); Virginians Against a Corrupt Congress v. Moran, 805 F. Supp 75 (D.D.C 1992) (citizens filing complaint against congressman alleging violation of franking laws and regulations did not have standing in federal court because they did not exhaust administrative remedies). 200 See Owen v. Mulligan, 640 F.2d 1130 (9th Cir. 1981); see also Common Cause v. Bolger, 512 F. Supp. 26 (D.D.C. 1980); Barbara J. Van Arsdale et al., supra note 161, at § 63:73. 201 See Schiaffo v. Helstoski, 492 F.2d 413 (3d Cir. 1974); see also Barbara J. Van Arsdale et al., supra note 161, at § 63:73. 202 Injunctive relief is when a court orders an individual to perform or cease certain behavior rather than imposing monetary damages. It is considered an extraordinary remedy. See Injunction, Legal Info. Inst., https://www.law. cornell.edu/wex/injunction (last visited June 14, 2016). 203 See Barbara J. Van Arsdale et al., supra note 161, at § 63:73 (citing Hoellen v. Annunzio, 348 F. Supp. 305 (N.D. Ill. 1972), judgment aff’d, 468 F.2d 522 (7th Cir. 1972); Owen v. Mulligan, 640 F.2d 1130 (9th Cir. 1981); Caprio v. Wilson, 513 F.2d 837 (9th Cir. 1975)). 204 See Leah Sellers, supra note 199, at 145. 205 See id. 206 See Matthew E. Glassman, Franking Privilege: Historical Development and Options for Change, Cong. Research Serv., 22 (2015). 196 24