Comments:

The 98% of spammers who now violate the CAN -SPAM Act will violate a Do Not Email Registry and will violate a subject line labeling requirement. The FTC should waste no resources on these. All resources should go to development and implementation of new methods of enforcement. In particular, using its authority under the CAN-SPAM Act or its general authority, the FTC should: (1) develop a method to warn credit card companies and other engaged in money transfers that particular transactions originated in spam violating the CAN-SPAM Act, and (2) promulgate a rule making it an unfair trade practice to facilitate or receive money transfers for transactions that originated in spam violating the CAN-SPAM Act.