Comments:

With regard to defining primary purpose violation triggers, one could rather quickly compile a list from consumer recipients of solicitation and have the regulatory officials compare the suspect items to that database. In terms of changes, a large portion of the SPAM is offshore and provisions should regulate that as an issue of national security since SPAM is also a vehicle for invasive electronic technologies like viruses and worms which threaten the integrity of US computer systems and information infrastructure. there could in fact, be a concomitant ratcheting up of penalties if this is recast as less an annoyance, bust as an issue related to homeland security. Opt-out should be immediate since the SPAM is. The meredecreasing of the requirement in terms of days requires more maintenance by mailers and serves as a disincentive for violations. Repeat offenses should be treated as aggravating warrants for each count of violation. The effectiveness of the ACT must be tracked to see that it is not moribund like the last federal anti-SPAM legislation which ignored the international dimension previously discussed. The Anti-SPAM list should quickly be implemented and penalties adjusted doubling penalties for violating the act and the list as separate charges.