Comments:

Re: CAN-SPAM Act Rulemaking, Project No. R411008 In re: A. 1. (Other) The commercial advertisement or promotion in the email is the MAIN FOCUS of the email. In general: I am concerned about the proposed requirement for merchants to maintain suppression lists. There are too many problems and costs associated with this idea, and too much potential damage to consumers and businesses alike. Requirement of the use of suppression lists will overcomplicate the original, simple "opt-out" provision of the act. Technology to make suppression lists "interactive", which would be the ONLY way a consumer could truly be "opted out" of all entries into all lists seeded by the original "opt in" list, simply does not exist; and there is no standard in the industry upon which such could be developed. Thus it would be a mandate to do the impossible, and cause havoc in the industry. For example, many of the legitimate merchandisers available on the net share their respondents with others, but not through a shared list. Thus, if a certain consumer opted-out of one merchandiser's list, the other merchandiser(s) have no way of knowing this. So as long as a commercial email contains the required "opt-out" election at it's end, the consumers are protected and the use of suppression lists is not necessary. My specific concern is potential harm to merchandisers who are already complying with the Act by requiring permission from the consumer prior to adding them to any list, and use the "opt-out" election in each email. They're not who CAN-SPAM was designed to put out of business, but this requirement COULD have that effect. There's also the potential for significant harm to consumers, since these suppression lists WILL ultimately fall into the hands of spammers, leading to more spam instead of less. I am aghast at the potential problems this ruling could involve, and urge you in the strongest possible terms to cancel its implementation in light of those problems, Respectfully submitted, Michael Narcum Bullhead City, Arizona *REDACTED PERSONAL INFORMATION*