|Comment Number:||EREG-647 Docket:04-06268|
|Received:||4/26/2004 3:44:14 PM|
|Organization:||The Barnabas Institute|
|Agency:||Federal Trade Commission|
At the Barnabas Institute, our biggest worry concerns the proposed requirement for merchants to maintain suppression lists and disseminate them to other organizations that help us serve customers. We feel that complying with this requirement would be prohibitively expensive for us, as well as an ethical breach of the privacy of our customers. As President of The Barnabas Institute, I speak for a small religious nonprofit that publishes an email discussion group, an email newsletter, and email delivery of our web site ?blog.? We send these only to subscribers who request to be added to a specific list, and who confirm that they want our publication. Our assumption heretofore has been that only the list being unsubscribed should be affected by the current request from our subscriber. We see no way to discern whether dropping the email discussion list means that they no longer want to receive the newsletter or the blog or announcements about recent research reports, much less whether some site whose publications they subscribed to because of a link on our site should no longer interact with our person. If we have so much difficulty in knowing how to comply, what about other publishers who, like our little nonprofit, are trying to do the right thing? The CAN-SPAM requirements were designed to stop the ?bad guys,? but could end up putting us and other legitimate communicators out of business. This well-meant ruling seems likely to cause us very serious problems. I hope that you will reconsider its implementation. Thank you for taking the time to consider our comments.