Comments:

Schaeffer's Investment Research, Inc. is a permission only emailer that has built up a significant business based in part on the Internet. A significant portion of our revenue comes from permission - based email campaigns that offer subscribers the convenience of making purchases 24/7 from anywhere in the world. We have subscribers in 170 countries. We strongly feel that a proposed Do Not Email List would fail and would only damage legitimate email marketers such as ourselves. It would create a false impression among users that it would actually make spam disappear from their email boxes. As we have already seen, the CAN SPAM ACT has not reduced the volume of spam. Futher, such a proposed List would create an unnecessary additional expense and compliance burden for us. Such expenses would raise the cost of doing business without any counter-balancing gain. Following are some added concerns with a National Do Not Email registry: Most spammers won't adhere to the registry. CAN-SPAM enforcement is only now beginning, and tracking down the majority of spammers is difficult. The registry will create a near-impossible enforcement environment. The registry significantly risks being compromised and used to spam. There are numerous ways the data could be obtained by unscrupulous e-mailers. Once compromised, the registry can't be re-secured. A domain-wide suppression option could potentially kill legitimate e-mail marketing. A proposed option is for all domain owners to submit their domains for commercial e-mail exclusion. Such a process would be fraught with misuse. If implemented at the Internet Service Provider level, this could curtail significant amounts of legitimate e-mail. The proposal contains no exemptions for preexisting business relationships. An exemption for e-mail desired by recipients is necessary to ensure the continued efficacy of e-mail communications. Consumers would have false hopes about less spam. The registry would lead to millions of frustrated consumer complaints but no solution. While the National Do Not Call List was very effective in achieving the desired result, the world of the internet is vastly more technical with an untold number of ways that spammers might 'beat' any system for Do Not Email. Therefore, the FTC would waste resources dealing with complaints rather than enforcing more important aspects of the law. A clause should be considered to ensure state Do Not Email registries aren't created. Please do everything possible to avoid foisting this canard upon us! Christopher C. Binkert VP Marketing