Comments:

A3. It is commercial if the email is unsolicited, sells something and the recipient has no prior relationship with the sender. B1. Change in status should be limited to one and one follow-up per renewal period and only if the previous renewal period was succesful with that recipient. D1. Unsolicited emails that originate or seem to originate outside the US in order to bypass spam law enforcement. E.2.5 Error in my response. I don't know whether they should have to comply. E.2.8. Unsolicited email should be treated as severely as possible. All programs should be opt-in, and not opt-out.