Comments:

Goodmail Systems does not intend to specifically address the question of whether the FTC should implement such rules. However, in the event that the FTC concludes that subject-line labeling is important, Goodmail Systems wishes to comment on the implementation of such rules, namely that alternative labeling mechanisms should be permitted in place of subject line labels. In this case, Goodmail Systems recommends that any rules created for subject-line labeling allow for an alternative approach such as the use of an icon or other small graphical representation. Icons or other graphical representation could be used to convey the same meaning as an “ADV” label while 1) providing a better user experience, and 2) not overloading the message subject line with too many characters.