CAUCE North America
16 CFR Part 316; CAN-SPAM Rule: Rule Review; Request for Public Comments; Project No. R711010
CAUCE North America, the largest and oldest grass-roots anti-spam organization, appreciates the opportunity to comment on the FTC CAN SPAM rule. The FTC should review technical approaches for opt-out instructions that can be processed mechanically, such as those defined by the IETF's RFC 8058, and mandate their use as far as practical, certainly for commercial e-mail sent in bulk. Opt-outs should apply to all commercial mail from a sender. If the recipient affirmatively opted in to a stream of mail, such as weekly product specials, an opt-out would apply to that stream. The current ten days opt-out period is too long. The FTC should make it a week or less. We realize that the FTC cannot change the text of CAN SPAM, but we note that an opt-in rule, as in the European Union and Canadian laws, rather than opt-out, would be far more effective.