|Received:||6/8/2005 6:02:32 PM|
|Organization:||The Circle of Ezines|
|Agency:||Federal Trade Commission|
|Rule:||Definitions, Implementation, and Reporting Requirements Under the CAN-SPAM Act|
Comments:The 3 day rule will be impossible for my group of 37 e-magazines. We have lost income due to some of these changes. With universal un-sub, we comply. The problem is that we make a living as high quality, value advertisers.I started the Circle of Ezines almost 7 years ago. If an ad seller sells an ad..we do not require the buyer to subscribe. We have a few ad sales divisions. An example would be if a person buys a solo ad, that person's ad would be in multiple e-magazines. Some people want to subscribe JUST to see their ads then unsubscribe. We're multi-post advertisers. Buyers pay once and get multple ads in various ad divisions. What happens is that if they un-subcribe to one e-magazine, we are required to drop them from all e-magazines. That means they can't communicate with the customer who bought the ad. This results in an ad seller losing income.Some people have mailers that won't allow them to subscribe with the same email address. We lose our customers. We could never un-sub in 3 days with part-time publishers. My own income dropped 2/3 since we had to deal with these issues. Publishers and ad sellers have quit The Circle of Ezines. It's very difficult for us and I would appreciate your consideraion of the ezine publishing industry in these matters. We specialize in quality ezine advertising which is a much needed service for all online businesses. We're valuable to the online business community yet our future here remains uncertain even though we do follow all the rules, policies and laws. I appreciate the opportunity to express my comments.