Comments:

Re: CAN-SPAM Act Rulemaking, Project No. R411008 To the Commissioners, I applaud your efforts to curb the problem of unsolicited bulk email. However, I am concerned about the proposed requirement for merchants to maintain suppression lists. There are so many problems and costs associated with this idea, and so much damage done to consumers and businesses alike, that I feel I must urge you to consider this matter most carefully. Requirement of the use of suppression lists will seriously damage many of the legitimate publications available on the net. My specific concern is for harm to publishers who require permission from the consumer prior to adding them to any list. They're not who CAN-SPAM was designed to put out of business, but this requirement will very likely have 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. On top of that, these suppression lists could easily fall into the hands of spammers, leading to more spam instead of less. I was quite surprised at the potential problems this ruling could involve, and urge you in the strongest possible terms to reconsider its implementation in light of these problems. As the owner of a Safe List and Hostng Company and several other mailing programs, I am flabbergasted to read how this act, has the potential to close down my legitimate business. Even with double opt in and getting members explicit expression of agreement to receive email from other members, that there is no physical means for us as a Safe List Hosting company to monitor what emails contain what commercial product or promotion. The Act must stop illegal spamming without a doubt but to force legitimate Safe List and mailing companies to monitor what is sent through them is not practical and the onus must be on the individual sending such email through these mediums to comply. I ask you this... How are we supposed to know who has unsubscribed from what companies products, services or membership site? Will the FTC, publish each and everyones specific Opt-Out requests in a downloadable database. And if so will the FTC accept responsibility if someone claims they unsubscribed but that was not updated and reflected in the FTC database on every single individuals Opt-Out request. Who on earth would have the resources to have such a database for every single Internet user from all over the world! After all if I receive a flyer in my [offline] postal or physical mail box delivered by the postman and I didn't request it. It just gets put in the rubbish! Respectfully, Ronald Pumfleet Whangarei New Zealand