| Comment Number: | EREG-374 Docket:04-06268 |
| Received: | 4/23/2004 1:41:49 PM |
| Organization: | Harmony United GbR |
| Commenter: | Karma Singh |
| State: | Not in the US |
| Agency: | Federal Trade Commission |
| Rule: | CAN-SPAM ANPR |
| Docket ID: | [3084-AA96] |
| No Attachments |
Comments:
Karma SinghAm Wordel *REDACTED PERSONAL INFORMATION* 15. April 2004Federal Trade CommissionU.S.A.Dear Sirs,I have been asked to write to you regarding proposals to reduce spamming.I have been informed that it has been mooted to require all businesses selling online to keep a "suppression" list and I have been asked to comment upon this.Quite apart from the technical problems which many small businesses will have with complying with this requirement I cannot see what effect it could possibly have upon reducing spam. Now, being a German based group, one could argue that my interest in American spam is somewhat academic especially as spam is not yet a real problem here in Germany. However, unless we can learn from your American model, spam will become a big problem here.The fact is that companies spamming will simply ignore this requirement (just as I could with total impunity). There is no sanction in this proposal which could have any effect upon any members of our group of businesses were we to involve ourselves in spamming.But, spamming is not an end in itself but rather a means to an end. What is this end?The end or aim of spamming is to obtain money. The majority of the payments which spammers seek are by credit card. I believe that the following proposal is both technically feasible and would be effective.1) Any source sending more than (say) 100 emails per day would be required to purchase an FTC commercial email licence. A licence owner would receive an encrypted code which must be added to all emails. Unless this licence is present, the emails would be automatically blocked at the ISP level, i.e. never reach their targets.2) Any company seeking to procure payments for online goods or services must hold a current FTC commercial email licence whose validity would be automatically checked as part of the payment verification process. Without the licence, payment would be blocked.If the licence fees were on a sliding scale so that on the one hand they are no real burden for small businesses (say $10 for 1000 mails/day annual permit) and $10,000 for one million per day to make spamming a major financial investment which it as present isn't. The beauty of this system is that I (and, of course, extra-national spammers) could not ignore it as we could the suppression list proposal. If I want to mail potential customers in the U.S. and receive payments from them, then I need an FTC email licence.I wish you much success with your endeavours.RegardsKarma SinghGroup ChairmanHarmony United