|Received:||8/19/2004 7:50:40 PM|
|Organization:||self - webmaster with several sites under management|
|Agency:||Federal Trade Commission|
|Rule:||Definitions, Implementation, and Reporting Requirements Under the CAN-SPAM Act (NPRM)|
Comments:Any commercial content other than the transactional content should qualify an email as commercial in nature. For example: saying "contact me at www.xyz.com" has no commercial content while "get the best widgets at www.xyz.com" is commercial. The issue will be people wiggling under the law to sneak in ads, If you try to say the majority of space is commercial people will use larger print, links, etc. This is just like "bills" you get in the mail that have 20 pages of ads included. To avoid confusion, The FTC needs to be straight out and simple: Transactional mailings have no commercial content, Commercial mails may have transactional content. It is possible for a commercial message to have less than 1/2 commercial content - that is up to the mailer; any rule that would allow any commercial content to creap in to a transaction would make it totally unenforceable.