| Comment Number: | OL-103820 |
| Received: | 4/15/2004 10:08:00 PM |
| Organization: | |
| Commenter: | John Skaggs |
| State: | VA |
| 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. I myself am such a publisher and I require not only that the consumer provide permission but they must REQUEST the first email, then they must re-confirm their desire to be on my list ("double-opt-in"). I see no need why "little people" such as myself should be made to incur the great expense of maintaining a "suppression" list. Further more it seems obvious to me that the very nature of "double opt-in" puts all email in the group "transactional or relationship." I say this because I, and others like me, do publish our mailings to groups of people who with whom we are developing a relationship. Though we come together for the purpose of earning a living, the value of the relationships we build go far beyond that. Further I must say that a suppression list for email puts our country in danger of trampling the 1st amendment in a way that the national Do-not-call list does not. They're not who CAN-SPAM was designed to put out of business, but this requirement will very likely have that effect. 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, John Phillip Skaggs Jr. Waynesboro VA the United States of America