Comment Number: OL-103504
Received: 4/15/2004 2:00:52 PM
Organization:
Commenter: Alan Moroson
State: CA
Agency: Federal Trade Commission
Rule: CAN-SPAM ANPR
Docket ID: [3084-AA96]
No Attachments

Comments:

Re: CAN-SPAM Act Rulemaking, Project No. R411008 To the Commissioners, I 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. In my opinion and many others, there's no need for this type of mess because it won't do much to stem the tidal wave of spam you get. Those guys are not using suppression lists anyway. I'm also concerned about the FTC proposing that the only way to meet the requirement of putting your physical address in every business email will only be satisfied with a street address. If you work from home, that would mean the law requires you to put your home address in every single business email. Not good, especially for "women living alone". 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. There also seems to be another asspect of this CAN-SPAM Act, the fact that only businesses in the United States are going to be penalized! If I was a Canadian Citizen or a Citizen of Mexico - This CAN-SPAM Act has no authority over me at all. If I live in Germany or France or Belgium - you have no authority over me. What I'm getting at here is that only the "United States" citizen is being held accountable, and henceforth being punnished. Does this seem at all correct? Of course not. This will only cause the birth of another entrepreneurial business of "off shore" mailing services and purchases of over-seas business licenses. These other countries are no so short sighted and where there's a will there's a way. 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, and many more unforseen at this time. Respectfully, Alan Moroson California, United States of America