Google announced this in May.

"We have added a few restrictions to the Mail API to improve the
reliability and reputation of the service for all applications. First,
emails must be sent from email accounts managed by Google (either
Gmail, or a domain signed up for Google Apps). Second, we’ve reduced
the number of free recipients per day from 2000 to 100 for newly
created applications. Both of these will help ensure mail from your
application arrives at the destination reliably."

http://googleappengine.blogspot.com/2011/05/app-engine-150-release.html

Well, it doesn't seem to have made a difference because many mails to
specific providers are still not delivered reliably, as has been
documented multiple times in this group and elsewhere. Another
complaint about it was posted today. I had really hoped Google would
have DKIM in place for new billing to improve reliability.

http://code.google.com/p/googleappengine/issues/detail?id=3161

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