Comments:

Regarding Aggravated Violations - it should be considered aggravated when a Spammer sells your address to others after you have requested Opt Out. It should also be considered aggravated when Opt Out messages can be proven to not be handled properly (as in automatically deleted upon receipt). Regarding E1 2. - If it can be proven that the opt out company related the opted out email to the three other companies, then they all should be held responsible assuming the opt out information was available to the other three.