Comments:

Determining an email's primary purpose include: Number of recipients of an email which does not qualify as a "transactional or relationship message." (TORM) TORM that also advertise or promote a commercial product or service should be deemed “commercial” messages because this would be far too great of a loophole. It would be best to close it shut right from the start. Opt-outs should be processed within 24 hours - either automatically or via employees. "Aggravated violation" - false or invalid "Reply To" email address. "Multiple senders" - one, and only one, entity should be held accountable as sender. Opt-out mechanisms for "friend forwarded" messages are irrelevant - as long as the Reply To address is valid. "Valid physical postal address" must be the one given on the business license. Subject line labelling: Commercial messages that are not TORM must have a subject line that begins [UCM] Small businesses that cannot conform to the act should be barred from sending UCM.