Comments:

D. Identifying additional “aggravated violations”: Add intentionally falsifying the sender information. E.3 Issuing Regulations to Implement Various Aspects of CAN-SPAM --The inclusion of a “valid physical postal address”. My business is mail order/internet only. All of my transactions occur through my P.O. Box. The only other address I have to give is my home address and I feel that is unreasonable for privacy and safety concerns. On Implementing a system of reward for CAN-SPAM violations: The spam reporting already in existence on the net is

 fraught with errors. It is very common for people to report emails as unsolicited even when they have gone through a double opt-in process and received emails for some time. I'm concerned that offering rewards will only encourage this behaviour. On Subject line labeling: Requiring subject line labeling will make more difficult the task of determining the primary purpose of the email - informational or advertising. If it becomes subjective based on the recipients opinion then you are putting the business in an awkward position. I also believe that subject line labeling will unfairly penelize legitimate email by prejudicing it in the minds of the recipients before they enen open it. I appreciate your efforts to curb the problem of unsolicited bulk email. However, I am concerned about the proposed requirement for merchants like myself 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 myself and many other 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. See our readers have already asked and acknowledged that they want to receive material from us. Legitimate publishers are not who CAN-SPAM was designed to put out of business, but this requirement will very likely have that effect. The new regulation would make it too burdensome for smaller publishers such as myself to continue publishing. There is also the potential for significant harm to consumers, because of the problem of properly knowing their intent when they unsubscribe from a list. The proposed ruling would lead to more confusion with consumers rather than confidence. On top of that, these suppression lists could easily fall into the hands of spammers, leading to more spam instead of less. I personally would like to see more effort put into penalizing those who forge and hide who they really are when sending their bulk email. Especially when they use innocent third parties as source of their forgery. These are the people who are causing the harm. 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,