|Received:||3/29/2004 2:53:27 PM|
|Agency:||Federal Trade Commission|
A do not email registry would not only hurt legitimate business, it would do nothing to stop spam and may even help them to get a large source of email names. Below I list key reasons not to inact a 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 ISP 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. The FTC would waste resources dealing with complaints rather than enforcing more important aspects of the law.