|Received:||5/25/2005 10:19:09 AM|
|Organization:||Association of Information Technology Professionals|
|Agency:||Federal Trade Commission|
|Rule:||Definitions, Implementation, and Reporting Requirements Under the CAN-SPAM Act|
Comments:Anyone who would argue that it should take three days, or even more, to process an optout doesnt understand the technological processes involved. They also demonstrate why optout doesnt scale. If they really think optout takes that long, than we should convert to an optin standard instead. I run almost 100 lists for one non profit along with a smattering of others for other organizations. All of them are run using the confirmed optin standard. It takes seconds, not days, to remove myself from any list that I dont want on. Each message has a clickable link at the bottom for unsubscribing. Click on the link, receive a confirmation email a few minutes later, click on the confirmation link in that email, and a few seconds later, not days, the address I submitted is removed from the list. If the DMA's optout lists can not be run at the same response level, than they are defective and should not be the standard against which we measure the capabilities of the industry. I'm not sure how to configure a list to delay the removal of an address for as long as three days. I don't think it is technically possible. Further, optout doesnt scale. If one percent of the world's business sent one email per year to me without my consent, I would be spending my entire work week doing nothing but finding and complying with optout instructions. It is far easier to complain to the spammer's ISP the first time I get a spam, and then block spam friendly ISPs if and when they fail to terminate the spammer. Eventually, ISPs willing to host spammers will be universally blocked by the responsible side of the net, their businesses will fail, and Can-Spam would become irrelevant. I am already blocking substantially more spam than I receive by a margin of better than 100:1. That ranges from the typical advance fee fraud, copyright infringement, and porn spam to the so-called mainsleeze spam. We don't need legislation to block spam. We need ISPs who terminate spammers, and blocklists to deal with the ISPs who fail to terminate spammers. That technology is already available and working, inexpensively and effectively. Those lists include Spamhaus, Spamcop.net, SORBS, AHBL and the like as well as lists like mci.blackholes.us or china.blackholes.us that block entire companies or countries that lack the willingness to control their spammers.