FEC AO 2022-14

Sun Jul 31 16:11:07 UTC 2022

https://www.washingtonpost.com/politics/2022/07/29/republican-fundraising-google-spam/

-------- Forwarded Message --------
Subject: AO 2022-14
Date: Sun, 31 Jul 2022 12:03:20 -0400
From: William Allen Simpson <william.allen.simpson at gmail.com>
To: ao at fec.gov

https://www.fec.gov/data/legal/advisory-opinions/2022-14/

* Opposing the proposal as written. *

Permitting unsolicited electronic bulk mail advertisements from political
actors is an involuntary contribution from Gmail users.

Google's statement that the Gmail service is "free" for its users is
inaccurate.  As Google admits against interest, Gmail users are subjected to
advertisements and also may subscribe to the service.

Moreover, data transmission and storage costs are significant.

Political electronic bulk mail is distinguishable from physical bulk mail.
Electronic mail is receiver pays (via advertisements or subscription).
Physical mail is sender pays (via stamps or permits).

Therefore, this is not without cost to the recipient.  Google reports an
immense profit.

It is undesirable and unseemly to pay (via advertisements or subscription)
and then receive more bulk advertisements.

Support a requirement that all political and other bulk senders be "opt-in".

Support that that for every bulk message:

    The requestor must meet reputational thresholds and ensure that their
    messages are secure, filterable, and follow best practices for the user
    experience, including for example:
      (i) “one-click” unsubscribe, which enables a user to efficiently opt
      out of future communications;
      (ii) approving and following unsubscribe requests within 24 hours,
      which respects the user’s choice; and
      (iii) ensuring that all links in the message can be scanned by Google
      for phishing and malware detection, which helps to protect the user
      from harmful content.

At our residence, the US mailbox is positioned near the recycling bin.
Bulk mail generally goes directly into recycling without being viewed.
Sadly, receiver has to pay for recycling (via taxes).

Likewise, we expect unsolicited electronic bulk mail to go directly to
recycling (the spam folder is automatically deleted, recycling storage).
This is a helpful reduction in user data transmission and storage costs.

---

I have been a Gmail user for many years.

I am also a Google Fi customer.

Don't be evil.

William Allen Simpson
Ann Arbor, MI