| Comment Number: | OL-102041 |
| Received: | 3/29/2004 10:09:17 AM |
| Organization: | Analog Devices, Inc. |
| Commenter: | Paul Faria |
| State: | MA |
| Agency: | Federal Trade Commission |
| Rule: | CAN-SPAM ANPR |
| Docket ID: | [3084-AA96] |
| No Attachments |
Comments:
Federal Trade Commission Office of the Secretary Room 159-H 600 Pennsylvania Ave., N.W. Washington, DC 20580 Re: CAN-SPAM Act Rulemaking, Project No. 41108 – Do-Not-Email Registry Dear Mr. Secretary: On behalf of [COMPANY], I am responding to the request for public comments on the proposed National Do-Not-Email Registry. Analog Devices Inc. believes that a registry, if enacted, would have a negative impact on our business and industry. More importantly, we believe that such a registry would not solve the spam problem, and would divert significant taxpayer resources away from the primary focus of enforcing the CAN-SPAM Act. Following review of the Request For Information and Advanced Notice of Public Rulemaking, [COMPANY] believes these issues should be considered prior to implementing a National Do Not Email Registry. 1. All individuals who receive communications via e-mail from Analog Devices Inc. have provided consent to receive our information. There are currently no exemptions in the proposal for pre-existing business relationships. Such an exemption for email consented by recipients would be necessary to ensure the continued efficacy of email communications. 2. We strongly believe that reducing spam is in our company’s best interests. However, if such a registry fell into unscrupulous emailers’ control and used for spam, this would further exacerbate the problem and hurt our business. 3. Many of the proposed processes for establishing a registry, such as using a third party forwarding service, would place an undue burden on my business and hamper our abilities to use email efficiently and expeditiously. 4. One of the proposed processes for establishing a registry includes a domain-wide opt-out. Such a process may lead to significant amounts of our permission-based email being erroneously filtered, deleted, or sent to the FTC as a violation of the registry. 5. Our company believes that there are many technical, self-regulatory solutions being proposed, such as sender authentication systems, that coupled with legal enforcement can effectively solve the spam problem in the coming years without the need for such a registry. I sincerely hope my comments will dissuade you from implementing a Do-Not-Email Registry, as Analog Devices Inc. believes that such an initiative is not only unworkable but will have a negative impact on our business, and potentially the U.S. economy. Paul R. Faria – eMarketing Manager Analog Devices, Inc. *REDACTED PERSONAL INFORMATION*