Federal Trade Commission
Sixth Street & Pennsylvania Ave. NW
Washington DC 20580
Consumer Privacy 1997 -- Request To Participate, P954807
To whom it may concern,
The Voters Telecommunications Watch (VTW) wishes to participate in the second session of the June 10-13 workshop on Consumer Online Privacy with regards to the issue of unsolicited commercial email. Our submission will be the summarized results of the survey we will be unveiling soon regarding Internet users and unsolicited commercial email.
The survey is currently available on our website at http://www.vtw.org/uce/ and will address the following Workshop questions by collecting anecdotal evidence from Internet Service Providers and Internet users.
2.18 What costs does unsolicited commercial e-mail impose on consumers or others? Are there available means of avoiding or limiting such costs? If so, what are they?
The survey we have developed addresses the questions of cost in many different forms, both for Internet users and Internet Service Providers. This will give us a broad view of the problem, touching on many individuals and many people within the industry. We look forward however to the comments from Simona Nass of Panix (Public Access Networks) to provide us a close look at the actual costs as assessed by a particular ISP when dealing with unsolicited commercial email.
A. Cost to consumers
The costs to consumers of unsolicited commercial email fall into a number of broad categories that we have enumerated in the survey, including but not limited to: telephone toll charges, ISP connect time charges, and ISP download charges. Anecdotal information indicating the actual dollar cost to consumers will be gathered in the survey, and we are looking forward to sharing this information at the Workshop.
A.1. Telephone toll charges
For some Internet users, online access is not a free, flat rate telephone call. For those users, the proverbial "meter" is ticking when they are reading, or even deleting without reading, unsolicited commercial email. Therefore a high incidence of unsolicited commercial email costs them out of pocket.
A.2. ISP Connect Time Charges
There has been much discussion in the market about pricing of Internet access for both large (such as America Online) as well as smaller Internet Service Providers, such as Panix. The amount of time a user is connected to the system with some services is metered at a usually low rate (such as at $2.95/hour), and the time it takes to read and even delete unsolicited commercial email adds costs to the user.
A.3. ISP Download Charges
Although it is not a major part of the pricing model today, anecdotal evidence indicates that some Internet users are charged on a per-megabyte basis. Unsolicited email adds to this cost, forcing the user to pay more for their Internet service.
B. Costs to Internet Service Providers
It is certain that Internet Service Providers also incur a cost for handling, delivery, and problem resolution related to unsolicited commercial email. A portion of these costs are similar to costs estimates for any sort of problem resolution, such as computer security problems as they require staff time to clean up the mess.
In addition, however, there are overhead costs to the ISP for handling of junk email. Their services are being used to deliver such mail, and they are required to overbuild capacity to account for it. In particularly disasterous circumstances, they experience a loss of mail delivery service when the amount of junk email overloads their capacity to deliver other types of mail.
These problems happen at both ends of the pipe for ISPs. They not only have to deal with these problems when a sender from another ISP targets their users, but also when one of their own users decides to use their services to send such email.
The costs borne by Internet Service Providers are much harder to measure, and therefore we expect anecdotal responses.
2.19 Are there technological developments that might serve the interests of consumers who prefer not to receive unsolicited commercial e-mail? If so, please describe.
A. Methods of dealing with unsolicited commercial email
At this time, the technological innovations that allow consumers who prefer not to receive such email appear to be in their early stages. We know of several, but will be leveraging what we discover in the survey to learn more about what is out there, and more importantly, what consumers wish they had available to them. In general, we have found the following methods of dealing with unsolicited commercial email to be in practice today by Internet users:
A.1 Reading it or deleting it
Is it undeniable that a certain segment of the Internet community actually reads or simply deletes their junk email with a minimum of effort.
A.2 End user filtering based upon sender, subject, buddy list, or intelligent agent
Several popular email programs have the capability to perform email filtering, whereby users can segregate their incoming mail into various "folders" and "priorities" for later reading. In addition, these filters can also simply delete mail without the user having to read it.
The criteria for filtering can be anything within the message, from the name of the sender on a "buddy list", to a search for a specific string in the text (such as "MAKE MONEY FAST"). Filters, today, are not as user-friendly as would be required by a mass market solution.
A.3 Third party filtering solutions
Long viewed as an answer to the objectionable content issue, third party filtering solutions have also made their way into the email world, with several Internet Service Providers, including Panix and America Online, offering their users a way of keeping unsolicited commercial email from arriving in their mailbox at all.
Such solutions aren't perfect, and have a direct impact on the resources of the third party doing the filtering, usually an ISP. The effectiveness and resource requirements of such solutions are particularly interesting when considering how such a system will scale up to the entire Internet.
At this time, this survey is a joint project of VTW and the regional group, Electronic Frontiers Florida (EF-Florida). With the Commission's permission, we will probably add other co-sponsors to the survey before it is completed for inclusion in the materials at the workshop.
Please feel free to contact me if you have any questions about our participation.
Shabbir J. Safdar
Appendix A - Description of VTW
The Voters Telecommunications Watch (VTW) is a three year old public interest group dedicated to preserving civil liberties online in the areas of free speech, privacy, and access to government information. Viewed as the premier grass roots Internet group today, VTW often works with public interest groups on Internet issues on all ends of the spectrum. In the past VTW has worked on grass roots organizing issues with Americans for Tax Reform, the Center for Democracy and Technology, Computing Professionals for Social Responsibility, the Eagle Forum, the Electronic Frontier Foundation, and the Electronic Privacy Information Center. More information on VTW can be found at http://www.vtw.org/
Appendix B - Survey
A copy of the survey is attached in paper form. It is also available at http://www.vtw.org/uce/