| Comment Number: | OL-104988 |
| Received: | 4/19/2004 11:41:32 AM |
| Organization: | West Lamination Identification GmbH |
| Commenter: | Stephen West |
| State: | Not in the US |
| Agency: | Federal Trade Commission |
| Rule: | CAN-SPAM ANPR |
| Docket ID: | [3084-AA96] |
| No Attachments |
Comments:
Dear Sirs, We are writing to you from Germany and therefore located outside of your jurisdiction, but we still feel compelled to moral obligations and are very much against the concept of Spam. Spam has become a tremendous problem during the last few years, wasting time, resources and money. It is imperative that any solution to the problem should be simple and easy to implement. We are concerned that the proposed requirement for merchants to maintain suppression lists may end up making the Internet and email harder to use, rather than easier for both businesses and individuals. Furthermore, by complying with the proposals and sharing the opt-out data of 'unsubscribers' with third parties, we would be breaking European Privacy Laws and also our own privacy policy, thus losing our credibility. Publishers with unsubscribe mechanisms should be exempted from any suppression list regulations that may be passed. There are millions of legitimate, honest businesses like ours using email in their everyday communications worldwide. Any program implemented should be designed to stop those few bulk Spammers who send untargeted email to millions of addresses at a time, disregarding any desire on the recipient's end to not receive the message without harming the multitudes of people using the technology properly and conscientiously. There are so many problems and costs associated with this idea, and so much possible damage done to consumers and businesses alike, that we feel compelled to bring this matter to your attention. We respectfully request that you consider this matter most carefully. Our systems of commerce have quickly been entwined with the Internet and email. The wrong move could have a ripple effect with unforeseen and destructive consequences. Requirement of the use of suppression lists will seriously damage many of the legitimate publications available on the net. As a small business, we would not be able to keep up with the additional burden the technology of this system will require. In the end, the CAN-SPAM legislation will not only burden and destroy businesses like ours, but the average consumer as well, who will no longer be able to receive the free flow of information the Internet was created to distribute. The intentions of CAN-SPAM are admirable, but there is a very serious likelihood of it having disastrous results. Rather than lessen the number of unsolicited emails we receive, these suppression lists would be likely to be gathered and abused by the Spammers themselves, leading to more Spam rather than less. The Spammers are resourceful enough to cloak their whereabouts, or send their Spam from another country, beyond the reach of US laws. We therefore strongly urge you to carefully reflect upon and review the downside of this act, and reconsider its implementation in light of these serious problems. Respectfully, Stephen West WEST LAMINATION IDENTIFICATION GMBH CHILEHAUS A FISCHERTWIETE *REDACTED PERSONAL INFORMATION* HAMBURG GERMANY