Comment Number: OL-103563
Received: 4/15/2004 3:56:58 PM
Organization: Online Marketing
Commenter: Arthur Lane
State: MD
Agency: Federal Trade Commission
Rule: CAN-SPAM ANPR
Docket ID: [3084-AA96]
No Attachments

Comments:

Re: CAN-SPAM Act Rulemaking, Project No. R411008 To the Commissioners, I understand that you are investigating new legislation designed to decrease or out-right eliminate unsolicited bulk email. However, as a sole proprietor, I am concerned about any proposals requiring merchants to maintain and utilize suppression lists. There are so many problems and prohibitive costs associated with this idea. Enactment of this legislation, designed in the "consumer's best interests", will in fact cause an increase in time, resources and money to effectively market within the law. This will inevitably lead to higher prices, damaging consumers and businesses alike. Therefore, I urge you to take the time to re-consider and weigh the advantages and dis-advantages most carefully. The entire basis of internet commerce will be affected! Quite simply, let's look at just one problem that I call "synchronization". Many databases driving email delivery systems simply are not designed to respond in real time. In other words, a recepient may elect to opt-out from a service, but there may be multiple messages queued for delivery over a period of days or weeks. Also, the proposed requirement of the use of suppression lists will seriously impair delivery of existing services on the internet, disrupting existing dissemination of valid, desired, and timely communications. Since reputable businesses already utilize opt-in mechanisms, WE ARE NOT the entities the CAN-SPAM initiative is designed to put out of business. However, the proposed suppression requirements will very likely cause irreparable harm to us, and not affect spammers at all! There's also the potential for significant harm to consumers, because we will be unable to discern a consumers intent behind unsubscribing. In other words, are they just not interested, unhappy with the quality of content, or dissatisfied with our services? I am quite disturbed over the potential problems this ruling could create, rather than mitigate, and must recommend in the strongest possible terms that you reconsider its implementation in light of not just my few personal/entreprenurial concerns, but those that have yet to be identified. We are now a wired society, and you need to fully investigate the impact to our entire culture and the financial ramifications that will surely result. Respectfully submitted, Arthur Lane*REDACTED PERSONAL INFORMATION*