Comments:

To the Commissioners, We applaud your efforts to curb the problem of unsolicited bulk email. However, we are concerned about the proposed requirement for merchants to maintain suppression lists. As a small business based in Australia, building an online business to fund my retirement we are concerned with what appears to be arduous effort required for questionable results. There are so many problems and costs associated with this idea, and so much damage done to consumers and businesses alike, that we feel we 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. Our 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. Also, the SPAM Act 2003 as well as the Privacy Act 1988 Australian Parliament place provisions on information held and may well preclude compliance with the CAN-SPAM provisions. (NOTE: as we have just learned of these provisions we have had little time to access legal opinion on this as yet. We are 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, Re Post Office Boxes Whilst now use only my physical address as our postal address (to show via web site and email that we are a bona fides organisation, I operated other businesses since 1975 using a Post Office Box as our mailing address. In part this enabled early collection of business mail (important as one of my businesses was a Customs and Forwarding Brokerage.) Physical mail went to the PO Box and personal visits were to our Office address. Perhaps this needs to be clarified for the Acts' intended purposes. Regards Lance Scoular Key Directions *REDACTED PERSONAL INFORMATION*