| Comment Number: | OL-105243 |
| Received: | 4/20/2004 2:36:30 PM |
| Organization: | Dawning Truth |
| Commenter: | David Lucas |
| State: | Not in the US |
| Agency: | Federal Trade Commission |
| Rule: | CAN-SPAM ANPR |
| Docket ID: | [3084-AA96] |
| No Attachments |
Comments:
Hi Guys, Great job you're doing. Us Internet Marketer's truly appreciate your attempts to properly regulate our industry. My comments are as follows: 1. I have a concern with people who report SPAM for reasons of Self Interest rather than for reducing the deluge that we all face. Further with most of these SPAMMER's sending from outside the US, it looks like legit opt in marketers can be unfairly penalised by "bounty hunters". Further many people forget that they have opted into a list and could falsely accuse a legit opt-in marketer. The act needs a way to address this problem too. 2. I think that there may be an alternative approach to addressing the SPAM problem to all those discussed thus far. My opinion of this alternative approach is as follows: The fundamental motivation behind SPAM i.e. Unsolicited Commercial Email messages, is that someone somewhere is profiting. Almost all of these online transactions take place by means of Credit Card Transactions. In my opinion, instead of stopping the email messages, which just seem to be getting worse, rather stop the credit card transaction. One way to do this is to: 1. Get the Support of Visa and Mastercard (And perhaps other international credit card networks). 2. Insist that all credit card transactions have to take place from a Domain name, which is registered in the name of the beneficiary. I.e. My name is John Doe, so my domain name has to be registered in the name of John Doe. If I do not have a registered domain name, then I may not accept credit cards online, and any bank that processes these transactions will be at risk of suspension from Mastercard and Visa. Further most domain name registrations are paid by either credit card or cheque, giving an opportunity to cross check the validity of the details furnished. If you want to prevent the registration of domain names with false or stolen details or credit cards, you can put an automatic halt on domain name transfers for 30 days before they can be redirected to a hosting company. This will allow time to catch stolen cards. Next you get all banks to require Domain Name registration, details or even WHOIS proof before approving an online credit card vendor. For the Internet marketers who do not have their own merchant accounts, you can request that the third party payment company has to have a record of the Domain Registration details. They can then loose their license if they deliberately allow false domains to process credit cards. Again they can check the domain name details against the account of the person they are processing details for - as this is the name that cheques or are issued in. If a person hacks into a server and issues a redirect to their registered domain name, this act can be criminalized and all funds thus processed can be held by the bank. Visa and Mastercard can insist on this. This approach should help to reduce the problem considerably by making spam uneconomical and therefore not viable in the longterm. If you would like any more of my thoughts on this matter, please feel free to email me at *REDACTED PERSONAL INFORMATION* . Regards Dave