Comment Number: EREG-565 Docket:04-06268
Received: 4/26/2004 3:44:16 PM
Organization: N/A
Commenter: Marion Kummerow
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 sincerely appreciate all your efforts to curb the problem of unsolicited bulk email. It does so much harm to everyone.However, I am concerned about the proposed requirement for merchants to maintainsuppression lists.The requirement to use suppression lists willseriously damage many of the legitimate publications available on the net. My specific concern is for harm to publishers who require permission from the consumer prior to adding them to any list. Either single-opt in or more strictly (f.e. for my newsletter) double-opt in. In this case readers have explicitly theri permission to receive email AND they have confirmed this permission.They're not who CAN-SPAM was designed to put out of business, but this requirement will very likely have that effect. Whereas it most probably won't have any effect on the spammers, because most likely their merchants (maybe they're their own merchants) don't even have a suppression list.There's also the potential for significant harm toconsumers, because of the problem of properly knowing their intent when they unsubscribe from a list. If I unsubscribe from a list, why would I care to tell the owner the reason? It just makes me go through addittional hassle. Maybe I don't like to tell him that some of his writing annoyed me, or a bad joke hurt my feelings, or I don't have anymore time, or I'm too stupid to understand his writings....On top of that, these suppression lists could easily fall into the hands of spammers, leading to more spam instead of less.I was quite surprised at the potential problems thisruling could involve, and urge you in the strongestpossible terms to reconsider its implementation in light of these problems, Respectfully,Marion KummerowGermany