Generally Gmail spam folder receives several false positives each week, maybe some 5% of all detected spam.
Even more worrying is that both gmail and IBM hosted mailservice reject legitimitate mail before SMTP is complete. (I have seen this in logs often enogh, although I don't follow them systematically)
Obviously they have overlooked in their spam filters that mail can be forwarded automatically. So if a Paypal message is forwarded and arrives from a non-paypal server, it must be spam. If your forwarding server forwards a couple of spam messages, subsequent legitimite message might be rejected, because this server sends too much spam.
Yes, spam is down from 20 a day to maybe 5 a day for me. But how much much is caused by rejection during SMTP, I really don't know.
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