Network Working Group T. Gavin Request for Comments: 3098 Nachman Hays Consulting FYI: 38 D. Eastlake 3rd Category: Informational Motorola S. Hambridge Intel April 2001 How to Advertise Responsibly Using E-Mail and Newsgroups or - how NOT to $$$$$ MAKE ENEMIES FAST! $$$$$ Status of this Memo This memo provides information for the Internet community. It does not specify an Internet standard of any kind. Distribution of this memo is unlimited. Copyright Notice Copyright (C) The Internet Society (2001). All Rights Reserved.
AbstractThis memo offers useful suggestions for responsible advertising techniques that can be used via the internet in an environment where the advertiser, recipients, and the Internet Community can coexist in a productive and mutually respectful fashion. Some measure of clarity will also be added to the definitions, dangers, and details inherent to Internet Marketing. 1. Introduction .............................................. 2 2. Image and Perception of the Advertiser..................... 4 3. Collateral Damage ......................................... 5 4. Caveat Mercator ........................................... 5 5. Targeting the Audience .................................... 7 6. Reaching the audience ..................................... 8 A. Dedicated website or web page ........................ 8 B. "Shared" Advertising website ......................... 9 C. Netnews and E-Mailing list group postings ............ 10 D. Compiled E-Mail Lists ................................ 11 7. Opt-In Mailing Lists ...................................... 12 A. Privacy ................................................ 13 B. Integrity .............................................. 13 C. Protection ............................................. 16
8. Irresponsible Behavior .................................... 16 9. Responsible Behavior ...................................... 17 10. Security Considerations ................................... 19 Appendices .................................................... 20 A.1 The classic Pyramid .................................... 20 A.2 What about Ponzi? ...................................... 22 A.3 So all multi-levels are evil? .......................... 22 B.1 Why Web Privacy? ....................................... 23 References .................................................... 25 Authors' Addresses ............................................ 26 Acknowledgments and Significant Contributors ................. 27 Full Copyright Statement ...................................... 28 1]). To understand why such activities are irresponsible, one must first understand the true cost and ramifications of such actions. The protocols and architecture upon which the 'Net is built, which are recognized and adhered to as standards, provide for an openness and availability which foster and encourage easy communication.
These standards were developed at a time when there was no need to consider the concept of "rejecting" information. While those standards have evolved, they continue to emphasize open communication. As such, they do not associate costs or impact with the user-initiated activities which may occur. Because of this openness, persons can and do send large volumes of E-Mail, with little-to-no cost or financial impact for the volume of messages sent. Needless to say, this presents the attractive option (to those who would consider such activity) of multiplying the recipients of their marketing material, and presumably, increasing their success- rate. However, and to reiterate an earlier statement in this text, there is a cost to be incurred at some point in this communication relationship. In the case of E-Mail advertising, since the cost of operation does not increase on the part of the sender, it must therefore increase on the side of the recipient. And it does. Every recipient of every E-Mail message bears a cost, either direct (cost per message received, an incremental increase in connection charges) or indirect (higher service fees to recoup infrastructural costs associated with the additional 'Net traffic which such mass-mailings create). In addition, other resources, such as the disk space and time of the recipient, are consumed. Because the recipients have no control over whether or not they will receive such messages, the aforementioned costs are realized involuntarily, and without consent. It is this condition (the absence of consent to bear the costs of receipt of a mass- distributed message) that has shaped the Internet Community's viewpoint - that the act of sending spam constitutes a willful theft of service, money, and/or resources. Those who choose to ignore the financial impact, and instead focus on the consumption of indirect resources, have been known to label spam "Internet Pollution". The Internet provides a tremendous opportunity for businesses, both large and small. There is certainly money to be made using the 'Net as a resource. This paper recommends practices and ways to use the Internet in manners which are not parasitic; which will not, by their mere existence, engender predetermined opposition, litigation, or other negative conditions. This paper does not guarantee freedom from those, or other negative responses - rather, it provides the reader with a framework through which the marketer/advertiser and the 'Net community (and more importantly, the seller's target market) can coexist as well as possible.
2] - The damage or loss of credibility in the advertisers market  - Loss in advertiser's and/or seller's Internet connectivity (most service providers have strict "zero tolerance" policies which prohibit the use of their systems for the sending of spam, or for encouraging or enabling such activities) - Civil and Criminal litigation. In the United States, (and progressively in other sovereign states), it has become accepted as fact that the theft-of-service associated with spamming often constitutes an unlawful use of private property and is actionable as trespass to chattels (a civil law term tantamount to "theft") in civil court  . It is a fundamental tenet to any Internet presence that a party will be responsible for their Internet "image", or the personae that they create. If an advertiser sells a product which is enjoyed by many, and the advertiser has not alienated, offended or angered a disproportionately larger number of uninterested recipients, that advertiser could be viewed as a hero. Conversely, an advertiser broadcasting their product to millions of uninterested parties, at the parties' cost, will earn the advertiser the moniker of "spammer", thief, or other less attractive names. The advertiser will be held responsible for those actions, and the effects those actions have in the marketplace, which is to say, the 'Net community. "On the Internet, nobody knows you're a dog."  That was the caption to an illustration published in the 1990's. The message is clear - the Internet renders all parties anonymous. The methods used to sell products in the traditional sales channels - language, image, relationships, eye contact or body language - no longer apply when measuring an Internet sale. Reputation, reliability, honesty, trustworthiness, and integrity have taken the place of the more
direct sales approaches that have been previously used. These are dictated by the rate at which both information and misinformation travel on the Internet. And, just as an Internet user cannot control what messages are sent to them, neither can the Internet marketer control the information that is disseminated about them, or their activities. Some information will circulate that is not accurate. Perhaps there will be cases where there will be information circulating which is downright incorrect. But, a successful market reputation, based on ethical behavior, will render the inevitable piece of misinformation meaningless. For an advertiser to exist responsibly on the Internet is for the advertiser and seller to take active responsibility for their actions.
- In many countries, providing such material to under- age minors is a crime. As the provider of the link, the advertiser's position is tenuous. - In some countries, such material is a crime to view, possess, or distribute ("trafficking"). As the website owner or advertiser, a party engaging in such activities must consider the ramifications of international law. To prevent such risk, advertisers should qualify the recipients of their advertising. However, it must be noted that E-Mail addresses provide little useful information to that end. Remember, "On the Internet, nobody knows you're a dog." Advertisers will have no way to qualify a prospective recipient as an adult with complete discretionary and plenipotentiary authority. In other words, an advertisement targeting a high-income population in need of property investment opportunities may be sent to a group of school children. Or a dog. How then, does the prospective advertiser/seller determine the quality of their leads? The essential requirement is that the advertiser "know" their audience. As with all sales leads, the ones which are developed and generated by the advertiser who will use them are of the most value. There is an inherent value to collecting the data first-hand; by collecting the data directly from the prospective recipient, the advertiser can accomplish two important goals: - The advertiser ensures that the recipient is genuinely interested in receiving information. Thus, the advertiser can protect themselves from the negative impact of sending Unsolicited E-Mail ("spam"). - The advertiser maintains the ability to "pre-qualify" the lead. One interested lead is worth more, from a sales and marketing perspective, than millions of actively uninterested potential recipients. If an advertiser maintains an active website or uses other mass- marketing tools (such as direct-mail), and they are interested in pursuing Internet Advertising, the advertiser can add a mechanism to gather sales lead data in a relatively simple manner. From the perspective of Responsible Use, the only such mechanism to be discussed in this text will be the "Opt-In" concept, to be discussed in detail later in this document.
Regardless of the manner in which the information is gathered, there are certain steps which the advertiser must follow. The advertiser must inform the person that data is being collected. In addition, the reason why the information is being collected must be clearly stated. BE AWARE! There are jurisdictions which restrict the collection of Personal Data. The laws addressing collection and future handling of Personal Information will vary from place to place; advertisers must take steps to gain an understanding of those laws. Prudence should be the advertiser's guide. If an advertiser is unsure as to the applicability or legality of an action, both in the jurisdiction of the advertiser as well as that of the recipients, the action must be avoided entirely. Advertisers would be well advised to realize that, if they engage in spamming, they will inevitably break the laws of some jurisdiction, somewhere.
find those groups and lists. BUT UNDER NO CIRCUMSTANCES SHOULD AN ADVERTISER PURCHASE A MAILING LIST AND START MAILING! There are other reasons which will be addressed further into this document, but to engage in such activity opens the advertiser to the liabilities and negative ramifications previously stated. Such negative conditions cause increased costs to the seller/advertiser, when the risks (loss of connectivity, defense against litigation, avoiding discovery, etc...) are factored into an advertiser's overall operation. In short, it is in the best interests of the seller and advertiser to ensure that the proper audience is targeted, prior to any further steps.
creating such a website, there are numerous resources available to provide assistance. From no-cost avenues such as instructional websites; to low-cost resources such as books, videotapes or classes; to full-service businesses and consultants who can advise advertisers throughout the entire scope of the website/web page design, implementation and hosting process (or any part thereof), there is a solution available for every type of site and cost-structure. B. "Shared" Advertising website Advertisers have the option of placing their advertisements on a website operated by a third-party. For advertisers with an immediate need, such sites (also called "Electronic Malls", "E-Shops" or other names) have several advantages. In some cases, a shared site can be more cost-efficient than building a dedicated website. Many sites will target a specific market (refer to Section 5 of this document). By using existing resources, advertisers can avoid the cost and burden of owning their own site. Many websites will target a specific advertisement to a specific audience, thus providing much of the research for the prospective advertiser, and providing the advertiser the means with which to reach the most receptive audience. Additionally, advertisements from such advertising sites can be integrated into a larger context, such as supporting free e-mail services, Internet access, or news broadcasts. Such integration can lend a level of credibility to an advertising effort that might not exist otherwise. Some notes on the use of any type of website for advertising: Regardless of what method an advertiser chooses to use for for advertising on the Web, there are some specific caveats regarding customer interactions: First, the advertiser must ensure that their contact information - name, phone, e-mail address - are all clear and available; Second, advertisers should take care in creating forms which gather information about customers, as there is concern in the United States and other countries about gathering information from minors without parental consent. There is also concern about grabbing dynamic information via persistent state information, such as through the use of "cookies" or through data collection software resident on the user's computer without their knowledge.
advertisements. Advertisers who fail to meet those requirements will be undertaking irresponsible behavior, and will be subject to the effects thereof. D. Compiled E-Mail Lists It bears repeating at this point: Let the Seller Beware. The material discussed in Section 4 of this document is particularly relevant in the consideration of E-mail, and the use of compiled lists of e-mail addresses for advertising. Advertisers should understand that they bear the responsibility for ensuring the proper targeting of their recipients; the proper display of their or their seller's identities; and the use of resources or systems only with the express permission of the owners of those systems. When faced with the task of collecting and compiling recipient information, one option that is frequently presented is that of pre-compiled mailing lists. Most often, these are advertised using the very method which is irresponsible, that of Unsolicited E-Mail. There are numerous reasons why these lists should not be used. Many suppliers create mailing lists from addresses which they have gathered in mildly to extremely unethical ways. Many of these list-makers rely on grabbing volumes of addresses without checking their legitimacy. In other words, they send out software robots to grab addresses they find in News or Mailing List archives which may be many years old! In addition, many list owners create addresses using a "dictionary", creating vast numbers of invalid addresses which are then sold to unsuspecting purchasers. People change jobs, change ISPs, and change everything about themselves over time; trusting a third party for a mailing list is just not wise. It is known that some mailing list providers have created mailing lists from E-mail addresses of people who have asked to be REMOVED from their mailing lists. They then sell these lists to other advertisers who think they're getting a list of people who will welcome the unsolicited information. Regardless of the source, however, advertisers and sellers bear the responsibility for maintenance of their lists. Purchasing a list from a third-party shifts the maintenance costs of that list onto the advertiser who uses it. Needless to say, this is only economical for mailing list vendor.
Given these conditions, all evidence points to the fact that the greatest level of control of an advertiser's own success and liability rests with the advertiser themselves. This being the case, advertisers are faced with the task of compiling their own lists of willing recipients of Advertising-related E-Mail messages. As discussed previously, those leads which are generated by the advertiser are the most likely to have an interest in the advertisement, so they are also the least likely to protest the receipt of such advertisements via E-Mail. It is this circumstance that makes the use of an "Opt-In" list (refer to Section 7 of this text) to be perhaps the most successful method of advertising distribution on the Internet. It must be noted here - for the same reasons that apply above, if an advertiser has compiled their own mailing list for their purposes, that list must NEVER be sold to another party. Just as it is considered unethical to purchase a third-party mailing list, it is equally so to be the provider of that list. Customers who wish to receive information about your product are not likely to respond favorably when contacted in an unsolicited fashion by your business associates; protect your reputation from the backlash of bad-faith that can occur in such cases. 10], which has a response rate of only 0.65%. It is so successful because the recipients of those E-mailed advertisements made a specific effort to receive them, thus indicating their interest in receiving information about products which the recipient felt were of interest to themselves.
Advertisers wishing to employ Opt-In mailing lists in their advertising can turn to several resources for assistance. If an advertiser operates their own website or web page, they already possess the most important facet, a web presence with which to invite participation in the Opt-In list. If the advertiser chooses to use a shared website for their product, they can also utilize an Opt-In data gathering mechanism. There are numerous forms and technologies that can be employed to build an Opt-In list - this document will not address them individually. Rather, the purpose of this section is to provide the advertiser with information which, when used, will help protect the advertiser, and make the advertising experience a successful one. A. Privacy As stated previously, advertisers should take care in gathering information from Opt-In participants. First and foremost, the person providing the information must be aware that they are doing so. By taking these preliminary steps, an advertiser decreases the risk of having any messages interpreted as spam. If, in submitting information for any purpose, the advertiser intends to use the submitted or inferred data for any mailings, there should be clear language indicating so. Furthermore, persons submitting data must be given the choice to "Opt-Out"; that is, to choose to submit the data but NOT receive any advertisements. A safe course of action is for the advertiser to configure their data-gathering so "Opt-Out" is the default; that is, to ensure that any members of the list have made a concerted effort to get onto said list. In nearly all cases, merely having a "check-box" available with the caption "Please send me E-Mail advertisements or announcements about your products." is sufficient. It is crucial that advertisers be aware that different jurisdictions deal with the collection of personal data differently - the burden of verification of these laws rests on the advertisers. For additional information on privacy, refer to Appendix B of this document. B. Integrity When maintaining a list where names can be submitted via some type of public or semi-public resource, such as a website, advertisers should take steps to verify every subscription to
that list. There are key pieces of data that can be used to verify the integrity of a particular subscription request, but the only person who can attest to the genuineness of the actual act of subscribing is the owner of the E-Mail address which has been submitted. To protect themselves from the risk of inadvertently spamming an unsuspecting recipient, advertisers should immediately confirm any submission. In doing so, advertisers can satisfy all requirements for responsible confirmation of a subscription request. In addition, if a person's E-Mail address has been submitted to a list without the knowledge or permission of the owner of that E-mail address, immediate notification of that, and the receipt of supporting data, enables the owner of that account to act accordingly to protect their account from future wrongdoing. When generating confirmations, the following information must be provided to the subscriber: - the E-Mail address subscribed - the manner in which it was subscribed (website or mailing list address) - the Date and Time of the subscription request (via NTP, for uniformity in future reference) - the IP Address of the host which submitted the request - the full headers of the subscription request (where applicable, such as mailing lists) - the Name, website address, and contact E-Mail address of the advertiser - instructions to the recipient as to how to permanently remove themselves from the list In addition, a well-represented business will make an effort to communicate this material in a way which the average recipient can understand and relate to, such as the following example :
- - - - - - C O N F I R M A T I O N - - - - - - - - - - - - Thank you for your interest in Widget Sales! This is confirmation of your subscription request for the Widget Sales E-mail list. You are currently subscribed with this address: email@example.com Your request was received via our website at http://www.example.com/input.html If you did not submit this request, someone may have submitted it for you, or may be pretending to be you. If you wish to be removed from this list, Reply to this message with the word UNSUBSCRIBE as the body of the message. If you feel you were added to the list without your permission, the information below should be forwarded to your ISP's Administrative staff for follow-up, with an explanation of your concern. As stated in RFC-2635, "you can do this by sending mail to "Postmaster@your-site.example". Your postmaster should be an expert at reading mail headers and will be able to tell if the originating address is forged. He or she may be able to pinpoint the real culprit and help close down the site. If your postmaster wants to know about unsolicited mail, be sure s/he gets a copy, including headers. You will need to find out the local policy and comply." Widget Sales, Inc. | http://www.example.com Responsible Internet | firstname.lastname@example.org Marketing - Made Easy! | email@example.com ----------------------------------------------------------- Submission Information: Request received for firstname.lastname@example.org from 192.168.0.1 at 06:41:55:13(GMT) on 07.03.1999 via http://www.example.com/input.html
E-Mail headers follow: Received: from 01.anytown.dialup.example.net ([192.168.0.1]) by adshost.example.com (FooBarMail v01.01.01.01 111-111) with SMTP id <19990703054206.VDQL6023@77.anytown.dialup.example.net> for <email@example.com>; Sat, 3 July 1999 01:41:55 +0000 From: Customer <firstname.lastname@example.org> To: email@example.com Subject: Submission Request Date: Sat, 03 July 1999 01:41:55 -0400 Organization: Zem & Zem Bedding Company, Inc. Reply-To: firstname.lastname@example.org Message-ID: <k???12qelNxp7Q=??3dbgLHWTLv@4??.bar.example> X-Mailer: FooBarMail HTTPMailer Extension 1.0.532 MIME-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: quoted-printable C. Protection Advertisers should be advised of certain measures they can take to protect themselves. Frequently, and especially when the traffic on a particular mailing list is low, a subscriber may forget that they had requested membership on that list. When a new message is sent and subsequently received, said recipient may lodge a complaint of spamming. If this situation is multiplied by several recipients, the advertiser and/or seller risks losing their Internet access, even if they have acted responsibly throughout the process. For this reason, advertisers should keep an archive of all submission requests which are received. This archive should be kept as diligently as the advertiser's operational data, and should be similarly safeguarded. Having such requests available will protect the advertisers from any reports of spamming, whether they are malicious, or the result of a genuine misunderstanding. For reasons that should be obvious, those messages should remain archived for a period that lasts AT LEAST as long as the list remains active. While this is not necessarily a requirement for responsible behavior, it is a measure of safety for the responsible advertiser.
assist the advertiser in creating a favorable environment for their work; in ensuring that they maintain a responsible presence on the Internet; and in targeting the types of customer and the methods to be used to reach those potential customers. Given these steps, there are some actions which should be avoided as the basis for any Responsible advertising presence on the Internet. DON'T advertise money-making opportunities that can, in any way, be construed as Pyramid or Ponzi schemes. (For information regarding those types of "investments", refer to Appendix A.1 of this document.) DON'T forge E-mail headers to make it look as if the messages originate from anywhere other than where they really originate. Many domain owners have won litigation against advertisers who have used their domain name in an effort to conceal their true identity.  DON'T send out any sort of bogus message to "cover" the intended activity, which is advertising. In other words, don't pretend that a personal message from the advertiser to someone else was sent to a mailing list by mistake so that the body of that message can be used to advertise, as in this example: Dear Tony - had a great time at lunch yesterday. Per your request, here's the information on the latest widget I promised [...]. DON'T use overly-general statements such as "Our research shows you're interested in our product." Most recipients know this is usually a bogus claim. Use of it can rob any legitimacy that the advertisement may hold. DON'T create mailing lists from third party sources (see Section 6; Part D of this document, above). DON'T SELL MAILING LISTS!!! Enough negativity! Now for some helpful suggestions.
DO participate in mailing lists and newsgroups which discuss topics related to the particular product/service. Advertisers will find people of a similar interest there and many potential customers. So long as an advertiser isn't offensive in their interactions with these groups they can find their participation quite rewarding. DO ask people if they want to be part of any mailing list that is created. Advertisers must be clear about their intentions of how they plan to use the list and any other information that is collected. DO tell people how list data has been gathered. If recipients are signed up from a web page, make sure the prospective recipient is aware that they will be getting mail. Many web pages have getting mail selected as default. Our recommendation is that the default be that recipients do NOT wish to receive mailings - even if the prospective recipients find an advertiser's site of interest. DO respect the privacy of customers. Keep a mailing list private. For an advertiser to sell a mailing list is not responsible or ethical. In addition, if offering any type of online transactions, advertisers should take care to encrypt any sensitive information The addresses of the list members should never be viewable by the list recipients, to protect your list members' privacy. DO take steps to safeguard all of the personal information that is being taken from customers, such as Credit Card or other Payment information. Provide honest information regarding the methods being used to protect the customer's data. DO let recipients know how to remove themselves from a mailing list. Advertisers should make this as easy as possible, and place the instructions in every message sent. DO let people know for what purpose any data is being collected. Advertisers must ensure that their plans regarding data collection are legal. Advertisers and Sellers can check with the web site of the Better Business Bureau, which operates in the United States and Canada. (www.bbb.org) This organization has several programs and services which can help advertisers in those countries, and has other resources which will benefit advertisers of any nationality. "Advertisers should advertise responsibly the better mousetrap they have built, and the world will beat a path to their E-mail address."
Appendix "A" describes how these schemes work and some of the risks inherent in their operation and participation. For a topical review of Privacy law across multiple jurisdictions, including several sovereign nations, Appendix "B" provides some resources for advertisers or other interested parties.
(1) send no money to anyone else; and (2) find three other people and replace all the names on the list. But, presume that not just this participant, but everyone who ever participates decides to follow the "rules". To avoid the start-up transient, assume that it starts with one name on the list and for the next three layers of people, one name gets added and only after the list is up to four does any participant start dropping the "top" name. What does this look like after nine levels if everything works perfectly? The following table shows, for nine levels, how many people have to participate, what each person pays out, gets in, and nets. Level People Out In Net 1 1 0 $55,550 $55,550 2 10 $5 $55,550 $55,545 3 100 $10 $55,550 $55,540 4 1,000 $15 $55,550 $55,535 5 10,000 $20 $55,550 $55,530 6 100,000 $20 $5,550 $5,530 7 1,000,000 $20 $550 $530 8 10,000,000 $20 $50 $30 9 100,000,000 $20 0 -20 So if this scheme ever progressed this far (which is extremely unlikely) over 10,000 people would have made the "guaranteed" $50,000. In order to do that, one hundred million people (or over ten thousand times as many) are out twenty dollars. And it can't continue because the scheme is running out of people. Level 10 would take one billion people, all of whom have $20 to submit, which probably don't exist. Level 11 would take ten billion, more people than exist on the earth. Pyramid schemes are _always_ like this. A few people who start them may make money, only because the vast majority lose money. People who participate and expect to make any money, except possibly those who start it, are being defrauded; for this reason, such schemes are illegal in many countries.
It may also be worthwhile to look at the history of the organization and its founders/leaders. The longer it has been around, the more likely it is to continue being around. If its founders or leaders have a history of fraud or crime, a person should think very carefully before being part of it.
- Notice of Data Collection - Choice to Opt Out - Access to Data to rectify errors - Adequate Security of Information Database - Access to contact persons representing the data collector Notice that the practice of data collection authorization can be accomplished using something as simple as an automated response E- Mail message. Such notices should contain easily understood information about the collecting party's identity, and instructions as to how a customer can remove themselves from the collected population. This will help assure prospective customers that an advertiser is a business of integrity. Businesses that pursue international trade (do business across national boundaries, overseas, etc...) bear the risk of facing legal prosecution for personal privacy violations. The European Communities have legislation for the flow of Personal Information. If an advertiser is interested in pursuing business interests across borders, and particularly if a business intends to solicit and/or share Personal Information, the advertiser/seller must be able to guarantee the same privacy considerations as a foreign counterpart, or as a business operating in the nation in which the advertiser is soliciting/performing their business. Other countries and their legislation are shown below: Germany - BundesDatenSchutzGesetz (BDSG) France - Commision nationale de l'informatique et de libertes (CNIL) UK - Data Protection Act (DPA) Netherlands - Wet PersoonsRegistraties (WPR) Australia - Privacy Act of 1998 (OECD DAta Protection Guidelines) Canada - The Personal Information Protection and Electronic Documents Act
 Hambridge, S. and A. Lunde, "DON'T SPEW: A Set of Guidelines for Mass Unsolicited Mailings and Postings (spam*)", FYI 35, RFC 2635, June 1999.  Internet Spam / UCE Survey #1. http://www.survey.net/spam1r.html, July 24, 1997.  ISPs and Spam: the impact of spam on customer retention and acquisition. Gartner Group, San Jose, CA. June 14, 1999. Pg. 7.  CompuServe Inc. v. Cyber Promotions, Inc., No. C2-96-1070 (S.D. Ohio Oct. 24, 1996) (temporary restraining order) [WWW], preliminary injunction entered, 962 F. Supp. 1015 (S.D. Ohio Feb. 3, 1997) [WWW | Lexis | Westlaw], final consent order filed (E.D. Pa. May 9, 1997)[WWW]. http://www.leepfrog.com/E- Law/Cases/CompuServe_v_Cyber_Promo.html http://www.jmls.edu/cyber/cases/cs-cp2.html http://www.jmls.edu/cyber/cases/cs-cp3.html  America Online, Inc. v. Cyber Promotions, Inc., No. 96-462 (E.D. Va. complaint filed Apr. 8, 1996) [WWW] (subsequently consolidated with Cyber Promotions' action filed in E.D. Pa.).  Cyber Promotions, Inc. v. America Online, Inc., C.A. No. 96- 2486, 1996 WL 565818 (E.D. Pa. Sept. 5, 1996) (temporary restraining order) [WWW | Westlaw], rev'd (3d Cir. Sept. 20, 1996), partial summary judgment granted, 948 F. Supp. 436 (E.D. Pa. Nov. 4, 1996) (on First Amendment issues) [WWW | Lexis | Westlaw], reconsideration denied, 948 F. Supp. 436, 447 (Dec. 20, 1996) [WWW | Lexis | Westlaw], temporary restraining order denied, 948 F. Supp. 456 (E.D. Pa. Nov. 26, 1996) (on antitrust claim) [WWW | Lexis | Westlaw], settlement entered (E.D. Pa. Feb. 4, 1997) [NEWS.COM report].  America Online, Inc. v. Over the Air Equipment, Inc. (E.D. Va. complaint filed Oct. 2, 1997) [WWW] [NEWS.COM report], preliminary injunction entered (Oct. 31, 1997) [NEWS.COM report], settlement order entered (Dec. 18, 1997) [Wired News report].  America Online, Inc. v. Prime Data Worldnet Systems (E.D. Va. complaint filed Oct. 17, 1997) [WWW] [NEWS.COM report].  Steiner, P. "New Yorker". July 5, 1993. p.61.
 Spam slam -- opt-in e-mail gains favor. http://www.zdnet.com/zdnn/stories/news/0,4586,2267565,00.html. May 28, 1999.  Eastlake, D., Manros, C. and E. Raymond, "Etymology of 'Foo'", RFC 3092, April 2001.  Parker, Zilker Internet Park, Inc., Parker, Rauch, Texas Internet Service Providers Association & EFF-Austin v. C.N. Enterprises & Craig Nowak [WWW]. Available: http://www.rahul.net/falk/zilkerjudge.txt  Parker, Zilker Internet Park, Inc., Parker, Rauch, Texas Internet Service Providers Association & EFF-Austin v. C.N. Enterprises & Craig Nowak [WWW]. Available: http://www.jmls.edu/cyber/cases/flowers3.html  WebSystems v. Cyberpromotions, Inc and Sanford Wallace [WWW]. Available: http://www.jmls.edu/cyber/cases/websys1.html
Acknowledgements and Significant Contributors JC Dill email@example.com Barbara Jennings Sandia National Laboratories Albert Lunde Northwestern University April Marine Internet Engines, Inc.
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