Comments:

Re: CAN-SPAM Act Rulemaking, Project No. R411008 To the Commissioners, While I do agree with many aspects of the CanSpam act I am concerned about the proposed requirement for merchants to maintain suppression lists, specifically merchants who also host an associate, affiliate or referral program. While we do maintain a supression list for our own subscribers who would like to opt-out from any future email messages, it is another matter entirely for us to be required to enforce the same for any associate, affiliate or reseller promoting our products to their own opt-in lists or client bases. We have specified what is and isn't acceptable as far as promotions by our associates when they join our program. Our terms are straightforward and they are enforced. We are a responsible company with responsible associates who will only be hurt by the requirement of a supression list. Another area of concern is the technology required to maintain such a list. Most basic autoresponders used by legitimate online marketers do not have the ability to host supression lists to be shared by the company and their associates. Most basic autoresponders as they are today cannot allow a merchant to re-import the list after being "cleaned" without considerable inconvenience on the merchants behalf. There are import limits already in place to help curb the use of these systems by spammers or bulk email senders and any new technology needed to get a supression list system in place will only result in legitimate email marketers to undergo an additional monthly fee to cover the large cost of implementing such a system. We are the merchants with working, fully functional "remove" links at the bottom of our messages. We are the merchants with clear subject lines. We are the merchants sending email to specific people who filled out a rather lengthy form on our website to ask to join our mailing list. We are the merchants who include a valid, real physical mailing address at the end, or top of our email messages. We are the merchants who send our email only to the above mentioned people who, by their own choosing have decided to allow us to send them future offers for new products or services. We are the merchants who immediately honor any and all "remove" requests. And yet, your requirements for a supression list are going to directly affect us in a very hurtful way. There are so many problems and costs associated with this idea, that I must urge you to consider this matter most carefully. 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, Best Wishes, Lisa Edwardsen Duncan, British Columbia, Canada