|Received:||9/13/2004 4:18:38 PM|
|Organization:||Information Technology Association of America|
|Agency:||Federal Trade Commission|
|Rule:||Definitions, Implementation, and Reporting Requirements Under the CAN-SPAM Act (NPRM)|
Comments:As a leading association of the Internet industry, the Information Technology Association of America (ITAA) represents more than 375 member companies. We are firmly convinced that the continued growth of the “information economy” depends on providing consumers with tools to exercise their online preferences in a manner consistent distinctive interactive nature of online communications. The Information Technology Association of America has joined with approximately twenty other trade associations in comments prepared by Ron Plesser of Piper Rudnick regarding the above captioned proceeding. In addition to the points made in the joint “association” comments, we respectfully wish to underscore and elaborate on several essential points for the Commission's consideration. 1. Revise the standard for e-mail messages with content that is “commercial” and “transactional or relationship.” 2. Acknowledge that e-mail that is “pure” transactional is excepted from consideration as having a “commercial” primary purpose. 3. Evaluate the reasonable recipient’s expectation to opt out of messages with certain types of content.