|Received:||3/30/2004 5:08:52 PM|
|State:||Not in the US|
|Agency:||Federal Trade Commission|
The whole thing should be abandonded immediately! Commercial email differs from commercial postal mail only in that the middleman doesn't get paid. I would rather see your efforts going toward cutting down on the wasted paper in my postal mail. In addition, there are significant problems with the proposed DNE list, to wit: 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. A preemption clause should be considered to ensure state DNE registries aren't created. This type of proposal makes great election fodder, but the cost and difficulty of administering it effectively will give it a very negative rebound effect.