| Comment Number: | EREG-244 Docket:04-06268 |
| Received: | 4/23/2004 1:41:42 PM |
| Organization: | NetMan |
| Commenter: | Neeraj Varma |
| State: | Not in the US |
| Agency: | Federal Trade Commission |
| Rule: | CAN-SPAM ANPR |
| Docket ID: | [3084-AA96] |
| No Attachments |
Comments:
Re: CAN-SPAM Act Rulemaking, Project No. R411008To the Commissioners,I agree with your efforts to manage the problem ofunsolicited bulk email. However, I am concerned about the proposed requirement for merchants to maintain suppression lists.This requirement will cause a lot of work for online publishers while creating problems for consumers. For example: a person may subscribe for some information through one advertiser's offer and unsubscribe through another offer. Which request do we honour? Another example, if a person gets on a do not send list for a product on one day and then changes their mind and wants to receive the information later, publishers would be legally obliged to not honor the second request because they are on a suppression list.. The above are just a couple of quick examples. There are many problems and costs associated with this idea, and so much damage will be done to consumers and businesses alike. I urge you to re-consider this rule. Requirement of the use of suppression lists willseriously damage many legitimate publications on the net. My specific concern is for harm to publishers who require permission from the consumer prior to adding them to any list. They're not who CAN-SPAM was designed to put out of business, but this requirement will very likely have that effect.These suppression lists could easily fall intothe hands of spammers, leading to more spam instead of less.It would be sufficient to require "double opt-in" lists by publishers, where the consumer requests information then confirms that he/she really wants it. Many legitimate Internet publishers are already doing this and it works really well for subscribers too. The way you are setting up the system, it will create a lot of problems for everyone. I urge you in the strongest possible terms to reconsider its implementation in light of these problems.Respectfully,Neeraj VarmaAlberta, Canada