Comment Number: OL-104079
Received: 4/16/2004 11:14:20 AM
Organization: RSI, Inc
Commenter: Bryan Hix
State: AL
Agency: Federal Trade Commission
Rule: CAN-SPAM ANPR
Docket ID: [3084-AA96]
No Attachments

Comments:

To the Commissioners, Thank you for your efforts to curb the problem of unsolicited bulk email. However, I am concerned about the proposed requirement for merchants to maintain suppression lists, and how that information is to be shared. There are so many problems and costs associated with this idea, and so much damage done to consumers and businesses alike, that I must urge you to consider this matter very carefully. Requirement of the use of suppression lists will seriously damage many of the legitimate publications available on the net. My specific concern is for harm to publishers who require permission from the consumer prior to adding them to any list, referred to as "double opt-in" lists. When I double opt-in to a list I agree to receive their emails, advertising and all. If I find the content to be of no use or the advertising to be too heavy or inappropriate I simply unsubscribe. I realize they're not who CAN-SPAM was designed to put out of business, but this requirement will very likely have that effect. There's also the potential for significant harm to consumers, because these suppression lists could easily fall into the hands of spammers, leading to more spam instead of less. When I double opt-in to a mailing list I have read the site's privacy notice and am confident that my email address and other information will not be shared with anyone else. The sharing of suppression lists will do exactly that, as I understand the proposal. I was quite surprised at the potential problems this ruling could involve. My problem is not with advertising, per se. My problem is the growing volume of SPAM. Advertising-only emails (ex: online pharmacies, health supplements, pornography) seem to be the bulk of the problem. The double opt-in list email newsletters to which I subscribe have done an outstanding job of providing an easy subscribe and unsubscribe routine. I hope they will be able to continue to publish after your final ruling. Again, if I don't like their content or advertisements, I'll simply unsubscribe. This link is suggested reading from an experienced email publisher dated April 13, 2004; there are many other problems with this ruling. http://www.talkbiz.net/ramblings/weblog.php Thank you for the opportunity for discussion of this ruling, and I urge you in the strongest possible terms to reconsider its implementation in light of these problems. Respectfully, Bryan Hix Alabama, USA