Comment Number: OL-104091
Received: 4/16/2004 11:46:54 AM
Organization: Ardenlade Ltd
Commenter: Ian Robertson
State: Not in the US
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 wholeheartedly support your drive to reduce/eliminate unsolicited bulk email. But I have grave concerns about the proposal for merchants to keep suppression lists. I believe this measure will result in a major closing down of thousands and perhaps millions of small internet businesses who can not implement or afford to implement the proposal because of cost and substantial reduction of profit. And at the same time there will almost certainly be a big increase of SPAM from destinations outside the USA. This, on both counts, will be to the detriment of consumers, the very people that the measure is intended to benefit. And I therefore respectfully ask you to consider very carefully this matter and its implications to consumers and small entrepreneurial businesses as a whole. In particular, 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. 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 am very concerned at the potential problems this ruling could involve, even to me as a consumer of USA internet products and an affiliate living and operating outside the USA, and urge you in the strongest possible terms to reconsider its implementation in light of these problems. Yours faithfully, Ian Robertson Scotland, UK