Comments:

I thoroughly appreciate your intention and efforts related to curbing the problem of unsolicited bulk email. However, I am extremely concerned with the proposal requiring merchants to maintain suppression lists. There are so many problems and costs associated with this proposal resulting in much damage to consumers and businesses alike. I feel I must urge you to consider this matter very carefully and objectively. The requirement of the use of suppression lists will seriously hurt and restrict the legitimate publications available on the internet. My chief concern is the harm to publishers who normally require permission from the customer prior to adding them to any list. They're not the businesses CAN-SPAM was designed to impact negatively; but, this requirement will has a high probability of having that effect. There's also the potential for significant harm to consumers because of the problem of properly knowing their intent when they unsubscribe from a list. Additionally, these suppression lists could easily fall into the hands of spammers, leading to more spam instead of less. I was quite surprised at the possible ramifications this ruling could introduce, and urge you in the strongest possible terms to reconsider its implementation in light of these concerns.