Comments:

Re: CAN-SPAM Act Rulemaking, Project No. R411008 To the Commissioners, As a legitimate Internet marketer, I do everything I can do comply with the Can-Spam laws, and in fact applaud your efforts to curb the problem of unsolicited bulk email. However, I am concerned about the proposed requirement for merchants to maintain suppression lists. There are so many problems and costs associated with this idea, and so much damage done to consumers and businesses alike, that I feel I must urge you to consider this matter most carefully. Requirement of the use of suppression lists will seriously damage many of the legitimate publications available on the net. My specific concern is for harm to publishers who require permission from the consumer prior to adding them to any list. They're not who CAN-SPAM was designed to put out of business, but this requirement will very likely have that effect. It certainly will have a strong impact on my business. I make money, and help others to make money, by having affiliate programs for various products. Just one example is my www.DogTrainingZone.com site. This is a great product for people who want to train their dogs. Other marketers promote this site via an "affiliate link," and earn a commission on each successful sale. Unfortunately, if someone "opts out" of someone else's list when promoting my product, I have no mechanism whereby I can inform other marketers not to send emails for my product to this person . . . even though that person had legitimately opted in to that second list and explicitly given permission for that second list owner to send him or her emails. The administrative tasks involved boggle my mind, and would cut off a significant source of legitimate revenue from my business. Here's an analogy: Imagine that you did this on TV or radio. Everyone who didn't want to see another McDonald's commercial could say they don't want to be put on a suppression list. How on earth would the cable companies be able to run ads and be in compliance with the law? There is some similarity between this situation and the suppression lists. Don't get me wrong, I really want to block bulk emailers. I just don't want to do it at the heavy expense to legitimate web marketers that your suppression list would entail, myself included. There's also the potential for significant harm to consumers, because of the problem of properly knowing their intent when they unsubscribe from a list. On top of that, these suppression lists could easily fall into the hands of spammers, leading to more spam instead of less. I was quite surprised at the potential problems this ruling could involve, and urge you in the strongest possible terms to reconsider its implementation in light of these problems, Respectfully, Charlie Lafave charlie@DogTrainingZone.com www.DogTrainingZone.com Post Office Box 105 Novelty, OH 40072 tel: 440.564.1206