HELO RCPT TO QUIT MAIL FROM DATA - Federal Trade Commission
HELO RCPT TO QUIT MAIL FROM DATA - Federal Trade Commission
HELO RCPT TO QUIT MAIL FROM DATA - Federal Trade Commission
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<strong>Federal</strong> <strong>Trade</strong> <strong>Commission</strong><br />
receiving end have already been incurred by the time a subject line is<br />
available for filtering or blocking. 68<br />
Thus, if all senders of UCE – including fraudulent spammers – used a label<br />
in the subject line, and this label was used to filter out all UCE, ISPs would incur<br />
substantial bandwidth costs from receiving, storing, and processing the volumes<br />
of UCE.<br />
Indeed, representatives of the Internet Engineering Task Force (“IETF”) 69<br />
contended that subject line labeling may make it more difficult for computers<br />
to perform the necessary operations for sending, receiving, and filtering email. 70<br />
They argued that it can be difficult for a computer to perform multiple operations<br />
on a single subject line, 71 and that the more functions a computer is forced to<br />
perform on that subject line, the less effective it is at filtering. 72 Although IETF<br />
representatives clearly stated that they do not support subject line labeling, if<br />
Congress imposes such a requirement, then they recommend the label be placed<br />
in a separate header and not in the subject line. 73<br />
Finally, two participants at the FTC’s Spam Forum in 2003 and a<br />
representative of the ASRG observed that an English language labeling<br />
requirement might be meaningless to non-English speakers, although presumably<br />
any labeling requirement would require that a label be in the same language that<br />
the email was sent in. 74<br />
68. PrivacyClue: Everett-Church, 6.<br />
69. The IETF is an Internet-standards setting body.<br />
70. IETF: Malamud, 22-23; IETF: Moore, 19-20.<br />
71. For example, a computer may have to use the subject line to determine whether the email is in<br />
reply to a message, whether it is from a mailing list, and whether it has particular labels. IETF: Moore, 20-<br />
21.<br />
72. IETF: Malamud, 22-23. One member of the IETF submitted a proposal to the IETF outlining an<br />
alternative to subject line labeling that is currently on the standards track. IETF: Malamud, 24-25. See C.<br />
Malamud, A No Soliciting Simple Mail Transfer Protocol (SMTP) Service Extension, Sept. 2004, available<br />
at http://rfc3865.x42.com/.<br />
73. IETF: Malamud, 9; IETF: Moore, 17; IETF: Hardie, 28.<br />
74. KISA: Chung – Spam Forum (May 2, 2003), 115; Federation of European Direct Marketers:<br />
Tandberg – Spam Forum (May 2, 2003), 165; ASRG: Levine, 10.<br />
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