A beginning to control SPAM..

Rodney Joffe rjoffe at genuity.net
Mon Feb 24 19:05:14 UTC 1997

Ladies and Gentlemen - and others :-)

In the 'normal' world there exists a problem that you've all experienced
- it's commonly known as "junk" mail., and "junk telephone" calls.

As you all probably know (you're all so bright) before you can go after
someone for causing you harm, they have to break a law, or a rule. The
Federal Goverment, through various bodies (FCC and FTC) has enacted
certain rules that categorize certain unsolicited forms of communication
(mail, calls, fax) as being *wrong*.

They are helped by an international body that (unlike us!) actually has
enormous lobbying power. The body is a non-profit (501.c.3 I think)
known as the Direct Marketing Association http://www.the-dma.org . This
body has almost every major and minor direct marketer as a member, an
enormous operating budget, and a pot load of clout. They've helped the
feds draft rules. And their members have their sights aimed at the 'net.
Us. They believ(ed) that we'd make a great medium for them to send their
advertising (spam). Over the last year, I've managed to make them
sensitive to the fact that this is *not* a good idea. Of course, I don't
carry that much weight. But they have realized that it would be easier
to work with us than against us.

As a result, they have drafted the following position paper and rfc, and
I volunteered to post it here so that you can know where to go to make
your thoughts heard. Ignore the date.... it is still open for comment.

I urge you to respond to them. They have the clout to influence a lot of
the people who are already causing us problems

And please remember; I am *only the messenger, trying to help stop the
spamming*. At the conclusion of this email, I am in the same position as
y'all -- an unhappy recipient of SPAM. So don't try and involve me in
the argument because I brought a partial suggestion.


Rodney Joffe
Genuity Inc., a Bechtel company

1120 Avenue of the Americas, New York, NY 10036-6700 · 212 768-7277 Fax:
212 768-4546




Founded in 1917, the Direct Marketing Association (DMA) is the largest
trade association for businesses interested in direct marketing and
database marketing. A long-time champion of consumer choice, the DMA has
historically sought to ensure that consumers are afforded opportunities
both to learn about products and services of interest to them and to
express their preferences regarding marketers' use and dissemination of
information about them.

The sole purpose of this Request for Information is to determine the
feasibility of developing a service that will enable U.S. consumers to
opt out of receiving unsolicited commercial e-mail. The service would
provide the same benefit to consumers that DMA's existing preference
services provide in that they enable consumers to reduce the amount of
advertising mail or telephone marketing calls they receive at home. This
service could be modeled after DMA's existing services, described below.
DMA anticipates that this Request for Information is expected to lead to
a request for proposals if DMA, at its sole discretion, determines such
request to be in its best interest. However, DMA does not request
proposals at this time, nor can it make assurances that it will do so in
the future.

Please return information responses by close of business January 20,
1997, to the Direct Marketing Association, 1111 19th Street, NW, Suite
1100, Washington, D.C. 20036, Attention: Patricia Faley, Vice President
for Consumer Affairs. Please direct all inquiries to Patricia Faley at
(202) 955-5030 (telephone) or (202) 955-0085 or e-mail at:
patriciafaley at the-dma.org.


The DMA is the largest trade association for businesses interested in
direct marketing, which includes the use of databases. DMA represents
mere than 3,000 United States corporations as well as 600 corporations
from 47 other countries. DMA members use all media to reach their
customers and prospects - mail, telephone, direct response TV, radio,
home shopping networks, as well as cyberspace. A recently released
three-year study conducted by The WEFA Group found that in 1995 American
consumers purchased nearly $600 billion in goods and services, and
American businesses purchased nearly another $500 billion in goods and
services, via direct response (all media).

Over the years, DMA has initiated an array of consumer protection and
education programs. Among them, DMA adopted guidelines for ethical
business practice and established a peer review committee to respond to
cases of alleged guideline violations brought to its attention. It
published and distributed in 25 countries the DMA Fair Information
Practices Manual - a step-by-step "how to" manual designed to assist
businesses in developing and implementing companies' policies and
procedures on the use of information about consumers. And it established
the Mail Preference Service and Telephone Preference Service, which are
offered free of charge to give consumers the ability to remove their
names individually from the lists of major marketers, which reduces the
amount of advertising mail and telephone marketing calls consumers
receive at home.

Although many direct marketers are somewhat new to the business of
marketing on-line, DMA established a dialogue with its members,
policymakers, and cyber consumers about marketing in the new media. It
has disseminated to its members privacy principles developed jointly
with the Interactive Services Association, participated in Federal Trade
Commission workshops, and established a parents' page on its Web site
with hyperlinks to the sites of software vendors offering programs that
enable parents to take a more active role over what their children view
and do on the Internet. DMA also is developing a "how to" package, which
can be downloaded from its Web site, that will enable marketers easily
to create accurate and effective privacy notices for their Web sites.


In order to understand DMA's consumer choice philosophy and to
understand DMA's requirements for an E-Mail Preference Service (E-MPS),
it is helpful first to examine briefly the current Mail Preference
Service (MPS) and Telephone Preference Service (TPS). Please note that
it is not important that an E-MPS be identical in structure to the
existing services. In light of the capabilities of the new technologies,
DMA welcomes all suggestions for accomplishing the goal of reducing
unwanted mail.


DMA established the MPS name removal file in 1971 to provide consumers
with an opportunity to have their names removed from many national
mailing lists. DMA established TPS, a companion service, in 1985 to
answer increased consumer complaints and regulatory concerns regarding
the use of the telephone to market goods. Consumers are not charged for
registering with MPS or TPS.

Consumers register with MPS or TPS by postal mail. They register
directly; third-party requests are not processed because it is important
that each consumer has clearly made his or her own choice to reduce
their mail or call. Typically, consumers will not notice a decrease in
their volume of mail or number of calls until approximately 3-4 months
after their names are entered into the MPS/TPS systems. Consumer names
remain on MPS/TPS for five years and may be renewed.

When consumers register with MPS/TPS, their names are placed on a name
removal file. This "do not mail" or "do not call" file is made available
to business subscribers on either a monthly or quarterly basis.
Subscribers receive a "master" MPS and/or TPS magnetic tape in January
of each year. The January tape is complete, containing the names of all
consumers registered with the services. Upon receipt of the January
tape, all tapes from the previous year are discarded. The January tape
is cleaned of all records over five years old. Each subsequent quarterly
and monthly tape contains only those consumers' names and addresses
added during that month or quarter. Businesses subscribing mid-year
receive the complete tape plus updates.

List owners should use MPS/TPS before releasing any lists for rental or
exchange. A company that receives a rental list, which has not been run
against MPS/TPS, should do so before mailing or calling. Many companies
also use MPS/TPS through service bureaus. Service bureaus often run MPS
and TPS automatically against client tapes.

DMA guards against unauthorized use of the name removal file through
several means. First, before receiving the MPS or TPS tapes, potential
subscribers are required to sign contractual provisions limiting use of
the services to name-removal purposes only. Second, both MPS and TPS are
protected by sophisticated decoy systems designed to detect any misuse
or unauthorized access.


The objective of an E-MPS would be to provide a service that enables
individual U.S. consumers to reduce significantly the amount of
unsolicited commercial e-mail they receive. E-MPS probably will require
at least four key phases for DMA: registration and acknowledgment, data
maintenance, data distribution and data coordination with other

It is anticipated that consumers will register either at the DMA Web
site or via e-mail. The DMA forms for Internet registration at its Web
site could be duplicated for registration via email by consumers who use
dedicated e-mail services. It is essential that the registration data be
secure in transmission, storage, and maintenance.

Consumers will then receive a registration acknowledgment, which would
include a restatement of E-MPS policies and several reminders (e.g.,
that e-mail addresses must be updated for E-MPS to be effective).

The registration information will then be forwarded through secure means
to a Data Maintenance Center that maintains the data. Data maintenance
will include elimination of duplicate records and checking of e-mail
addresses to confirm that they are still valid. It may also include
deleting addresses that are more than a predetermined number of years
old. The Data Maintenance Center will then forward the E-MPS data to the
Data Distributor through secure means.

The Data Distributor will be responsible for distributing the E-MPS data
to authorized subscribers. The encrypted E-MPS data will be accessible
via electronic transfer to parties with a valid password. Subscribers
will be able to access complete files or only updates, which they would
be expected to download before each e-mail campaign or often enough to
ensure that they are being responsive to consumer requests.

There will be other ongoing activities in the operation of E-MPS. For
example, the Data Maintenance Center or some other entity might
periodically remind registered consumers of their status and furnish
them with an opportunity to remove their e-mail address from E-MPS. The
Data Distributor will also be responsible for operating a system
designed to detect any misuse or unauthorized access. For these and
other reasons, it would be desirable to consolidate all of the E-MPS
functions so as to enable consumers to register directly with the entity
responsible for data maintenance and distribution.

DMA is also interested in determining the feasibility of offering
consumers more flexibility in their opt out choices relative to e-mail
than which currently exists in MPS and TPS. For example, what
technological capabilities would be needed to offer consumers selective
opt-out, that is, the option of receiving e-mail from catalogue
companies, but not from auto parts manufacturers.

To further international cooperation in the implementation of the E-MPS
objective, it is anticipated that there will be both a global E-MPS Web
site and national E-MPS Web sites. The global E-MPS Home Page will have
language options and point to the national E-MPS Home Pages where
registration will take place. DMA has discussed creation of a global
E-MPS with direct marketing representatives from 20 countries. They are:
Argentina, Australia, Brazil, Canada, Finland, France, Hong Kong, India,
Ireland, Japan, Mexico, the Netherlands, New Zealand, the Philippines,
Singapore, South Africa, Spain, Sweden, Thailand, and the United
Kingdom. Over time, we expect that other countries would join our
discussions and our global self-regulatory network.


DMA seeks information that will help it determine the feasibility of the
funding, the development and the implementation of an E-MPS for U.S.
residents and, separately, of a global E-MPS. The information provided
by respondents to this Request for Information is expected to lead to a
request for bids if DMA, at its sole discretion, determines that it is
in DMA's best interest to request such bids or proposals. However, DMA
makes no assurances that it will request bids or proposals at any time
in the future. Information responses should not contain proprietary or
sensitive information, and DMA assumes no liability for protecting or
safeguarding any information provided.

The following questions explore issues DMA expects to address in
implementing an E-MPS. Commentary on additional issues is welcome.

1. 	The combined MPS/TPS files contain about 3.5 million names. How many
persons residing in the U.S. might be expected to register for E-MPS
during the first two years of its existence? Explain.

2.	 What information would be needed from consumers? Would it suffice
for registration to collect e-mail addresses, or would other identifiers
such as name and/or country be needed?	

3.	 What would be some of the approaches to verifying the identity of
the person registering for the service? How could DMA ensure that the
person requesting to opt out is the actual owner of the e-mail address?	
4.	 Due to the economics of sending bulk e-mail (unlike postal mail, the
cost between sending one e-mail solicitation and sending 1,000 nay be
inconsequential), it is important that the process by which e-mail
addresses are removed from lists be inexpensive and easy for the
e-mailer to use. To that end, the automating of the system for
registering e-mail addresses and disseminating the list is desirable. To
what degree would it be possible to automate the process of collecting
and accessing or disseminating e-mail suppression information? What are
the pros and cons of doing this? What other automation issues arise?	

 5.	 What are the special requirements for security other than using
seed names to detect misuse? How would other systems work?	

 6.	 What reports should the Data Maintenance Center furnish the DMA at
a minimum?	

 7.	 What are the global implications of such a service? In a medium
such as the Internet, is it feasible to create a localized system Out
will serve only residents of a particular geographic area, even if
through a common standard the system is capable of interacting with the
systems of other countries? Or should one entity operate a global E-MPS
for all of the direct marketing associations of the various countries?	

 8.	 What are your initial estimates, of costs for this E-MPS project if
limited to U.S. residents? If extended globally?	

9.	 What would be the timing for implementation of E-MPS (a) nationally
and (b) globally?	

10.	 What is the feasibility of offering consumer flexibility in their
opt out choices. For example the ability to reduce e-mail from a certain
category of marketer.	

11.	 In addition, we welcome any other suggestions or comments that
responders might have to address this issue.	

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