Comment Number: EREG-757 Docket:04-06268
Received: 4/23/2004 1:41:52 PM
Organization: My Net-Marketing Center
Commenter: Howard Moreland
State: GA
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,Your rule-making frightens me as I'm not sure any of you have the slightest idea about how to market using the Internet.I am concerned about the proposed requirement for merchants to maintain suppression lists.Like many great ideas, most end up back-firing or doing just the opposite of what they were originally intended to do.You see, I remember when such a body as your own created the "Inquiry" system for consumers when they reviewed their credit reports so THEY could find out who had been snooping around looking up their credit info.However, this back-fired "big-time." It ended up just being a way that creditors could label consumers with multiple inquiries as "potential risks!"I understand your reasoning, however it just needs to be thoroughly thought out.Applying the potential penalties an online business such as my own may suffer as a result of just one of my affiliate's failure (by accident or otherwise) to check his/her suppression list by analogy to direct mail, would go as follows:Sears mails me a catalog after I had requested to never receive any further solicitations from them, and the government steps in and just outright shuts down Sears!How ridiculous this would be!Sears provides countless jobs, boosts the economy, provides a limitless value to our society ... how dare someone shut it down like a facist just because someone asked not to receive a catalog from them.Well, maintaining suppression lists and being expected (even with one's greatest genuine efforts to adhere to them!) isn't even possible for most online enterprises; much less practical.I have a strict code regarding SPAM. (And I carefully admonish my associate marketers to abide by it!)And what if someone hates a particular company and merely joins as an affiliate with the intention of deliberately SPAMMING as many as possible just to get that company put out of business?This would be akin to someone in the 1930's or 1940's crying out "He's a communist!" just to see the proprietor put out of business, and family destroyed, and although the charge was without merit.Please, please, please: tell me that you would NOT have us revert back to such governmental "dark-ages!"I provide a valuable service and excellent digital products that are very much helpful to businesses and small business persons. Because of their publication (both directly by my firm, as well as through my army of affiliate marketers), the US economy is furthered, businesses and their owners (not to mention their respective families) live better lives realizing the "American Dream" (something that's nearly been left behind today!)It would be a travesty of governmental intervention if my firm were terminated by "Big Brother" just because of an accidental or uncontrollable oversight by one of my affiliates; or worse, by someone who just wanted to use such a law as "easy-leverage" in order to eliminate me and my business as their competition; and where they used the "Government" as their felloneous accomplice!I respectfully (as best I can) demand that as our leaders, YOU make sure you absolutely lead well and forge something of value; or else you do not deserve your positions -- nor the recognition or reverence afforded them.And in case you think I'm being bold, just change "suits" with me and see how you might feel about this intended law, if you knew the ones passing it may not thoroughly understand the market in which it is to be applied...Most sincerely,Howard L MorelandPresident, My Net-Marketing Center*REDACTED PERSONAL INFORMATION*