Comments:

To the Commissioners, It is certainly critical that laws are enacted to control unsolicited bulk email. However, I am concerned about the proposed requirement for companies and organizations 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. As a charity, we publish a Grief Support publication, Grief Matters, which you can read about on http://www.griefsupportservices.org/newgrief/resourcestocomfort/griefmatter/index.php. 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, Respectfully, Karen Russell, MA Executive Director National Grief Support Services CA, USA