answering with no insider knowledge, I just read the request, and the
reason for the request is in there, and matches what I expect... there are
strict rules
in the US about political donations, so making sure that this is not
considered a political donation is in the interests of Google on pain of
legal and monetary damages.

https://www.fec.gov/files/legal/aos/2022-14/202214R_1.pdf see page 10
"Discussion" starting with "Corporations are generally prohibited from
making contributions in connection with federal elections."

That section also discusses various other consultations that other tech
companies have made in somewhat similar veins, such as providing more
advanced login protection for political candidates.

The proposal also includes a section implying this level of extreme vetting
whitelisting could be expanded to other areas where bulk sending for legal
or other purposes would be required.   "If the pilot program proves useful
to users and pilot participants as informed by the feedback collected, it
may be adopted for senders in other scenarios, including potentially
expanding to government agencies, entities related to or involved in
providing government services, senders of class-action notices, and
nonprofit organizations. In this way, the pilot program is intended to
benefit a broader array of bulk senders, including non-campaign speakers."

As for those outside the US, I would be somewhat surprised if these
particular senders would have much spill over into non-US accounts, but
that would be a good thing for the team to keep track of.   Whether this
feature would come to political actors in other countries would have to go
through similar legal vetting on a per-country basis, since I'm sure most
countries have their own laws regarding this.

Brandon

On Sat, Jul 9, 2022 at 3:26 PM Jarland Donnell via mailop <mailop@mailop.org>
wrote:

> Is it normal to request such an opinion? As someone who doesn't follow
> business of the FEC but obviously takes interest in the topic, it seems
> odd to me though that may be due to the formerly mentioned thing.
>
> Earlier this year we saw a huge increase in email business resulting
> from Google's handling of free Gsuite accounts. Dare I say the rest of
> us might benefit from Google saying "You're going to take these emails
> and like it." I'll certainly not be quick to try to gain favor from any
> political parties by attempting the same.
>
> On 2022-07-09 14:53, Anne Mitchell via mailop wrote:
> > To those of you who aren't already aware of it, Google has asked the
> > Federal Election Commission for an opinion about Google's 'pilot
> > project' to allow political candidates and campaigns to bypass
> > Google's spam filters.
> >
> > This was just published by the FEC to the public yesterday, because
> > Friday is when they publish their "what happened this week" notice to
> > the public.  Here is the info:
> >
> > https://www.fec.gov/updates/week-of-july-4-8-2022/
> >
> > You can mail your comments to the FEC at a...@fec.gov.
> >
> > The window for comments closes this Monday, July 11.
> >
> > Anne
> >
> > --
> > Anne P. Mitchell, Attorney at Law
> > CEO Institute for Social Internet Public Policy
> > Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam
> > law)
> > Author: The Email Deliverability Handbook
> > Board of Directors, Denver Internet Exchange
> > Dean Emeritus, Cyberlaw & Cybersecurity, Lincoln Law School
> > Prof. Emeritus, Lincoln Law School
> > Chair Emeritus, Asilomar Microcomputer Workshop
> > Counsel Emeritus, eMail Abuse Prevention System (MAPS)
> >
> >
> >
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