On Mon, 25 Oct 2021, Laura Atkins via mailop wrote:

On 25 Oct 2021, at 02:33, John R Levine via mailop <mailop@mailop.org> wrote:

List-Unsubscribe: <https://www.example.com/unsub/{token}>
List-Unsubscribe-Post: List-Unsubscribe=One-Click

I don't know which fools to blame; The client Costco, or their ESP
WhatCounts.  Perhaps both.

Definitely both.

I don't work for or with WhatCounts, but I know who does, so I nudged them.

Considering that every message sent without working unsubscribe is a CAN SPAM 
violation, I'd think some tooling to check that the link at least connects to a 
server would be in order.

I don’t think a List-Unsub header is sufficient to comply with CAN SPAM.

Do you have better information from the FTC that suggests it does?

I would think that knowing you have a broken unsubscribe option and demonstrably failing to address the issue would provide a case to answer, but then I am not lawyer.

--
Andrew C. Aitchison                                     Kendal, UK
                        and...@aitchison.me.uk
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