Re: ATTENTION: DNSWL to be disabled by default.

2024-09-24 Thread Anne P. Mitchell, Esq.


> 
> Maybe disable VALIDITY rule as well... They also have 10k limit in 30 days 
> window ..
> 
> My understanding is that Validity returns a specific value (127.255.255.255) 
> for blocked queries. 

I kept going back and forth as to whether to jump in on this thread and point 
out that our own positive reputation DNSRL, the GSL - or as many of you know 
it, and as it appears in the rules, the IADB - has always been and will always 
be free to query or xfer, and with no restrictions, because we consider the 
receiving community to be with whom we have our allegiance, and to whom we owe 
responsibility.  After all, the founder (me) came out of MAPS, and I have 
always adhered to (and made sure that ISIPP SuretyMail adheres to) the 
strictest of standards before a sender can be certified with us and have their 
IPs placed on the GSL.

We are incredibly proud of and grateful for our relationship with the SA 
community.  In fact, the model of using discrete IP-address-based data points 
(which we pioneered and we knew others would copy, (which they did) and we were 
fine with that because it was a benefit to the receiving community which, after 
all, is the point) was designed *specifically* with SA in mind, so that SA 
could take full advantage of the granularity of the data;  this was designed by 
me and Craig Hughes.

Having run this by a trusted advisor in this community, I was encouraged to go 
ahead and post in this thread, so now I have.

Again, here is a clear statement:  The IADB ('GSL') is a positive reputation 
DNS-based list which is and always will be free to query, and free to transfer. 
 The only way for an IP to appear on the IADB is after strict vetting and 
making sure that the sender adheres to our own very high and strict standards.  
We also take spam complaints (the few we receive - only a handful a year) very 
seriously, and we have *zero* problem hitting a sender with a clue bat, and 
'firing' a sender if we find that they have veered towards the gray side after 
becoming certified with us.  (The fact that we charge a relatively small 
monthly sum to the senders makes firing them pretty painless. Thus it has 
always been - best practices over money *always* - we can take this stand 
because we are, always have been, and always will be, privately held, and the 
buck stops with me).

Anne

--
Anne P. Mitchell, Esq.
Email Law & Policy Attorney
Legislative Advisor
CEO Institute for Social Internet Public Policy
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal email marketing 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)






Re: Lots of FN because of VALIDITY* rules

2024-06-14 Thread Anne P. Mitchell, Esq.



> On Jun 3, 2024, at 4:09 AM, Matus UHLAR - fantomas  wrote:
> 
> I forgot to add that I have "lowered" (increased to small negative number) 
> scores for RCVD_IN_VALIDITY_*, RCVD_IN_DNSWL_* and RCVD_IN_IADB_*
> because I has similar bad experience with them.

Matus, if you EVER have a bad experience with RCVD_IN_IADB_ (or any other IADB 
test), *please* let me personally know asap. We take our responsibility to the 
receiving industry *very* seriously (always have, for more than 20 years now) - 
that's *why* we invented the data response code concept, and developed it 
specifically so that SA could take advantage of it (and didn't patent it so 
that others could use the concept to, again, assist receivers).  So, *please*, 
again, let me know personally, directly, if you ever find an issue with a 
certified sender (that is who would trigger the IADB tests) not doing the right 
thing!

Thank you,

Anne

--- 
Anne P. Mitchell, Esq.
Internet Law & Policy Attorney
CEO Institute for Social Internet Public Policy (ISIPP)
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal email marketing law)
Creator of the term 'deliverability' and founder of the deliverability industry
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)



Re: OT - Hotmail/Outlook.com marking most of our email as Junk

2022-02-19 Thread Anne P. Mitchell, Esq.
Cian, first, MailTester (and also the other automated systems) is notoriously 
bad about giving false negatives because so long as it finds *a* record (such 
as an SPF record) it considers it "ok"; this is why we've gone to a 
human-review system for test emails - I'd say in at least half the cases (if 
not more) MailTester gave the email a passing grade, including for SPF, and we 
determined quickly that the SPF was *wrong*.

if you'd like to send us a test email (no charge :-) ) send it to 
t...@gettotheinbox.com from the *same* system as you are wanting to test for 
deliverability (so *not*, for example, from your Gmail account), then send a 
second email to supp...@gettotheinbox.com from the email account at which you'd 
like to receive our findings, tell them Anne sent you :-), and in that second 
email tell them who the test email was from, and the subject line of the test 
email.

Anne

---
Outsource your email deliverability headaches to us, and get to the inbox, 
guaranteed! 
www.GetToTheInbox.com

Anne P. Mitchell,  Esq.
CEO Get to the Inbox by SuretyMail
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal email marketing 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
In-house Counsel: Mail Abuse Prevention System (MAPS) (Closed in 2004)

> On Feb 18, 2022, at 6:09 PM, Cian  wrote:
> 
> I am also having a world of trouble getting my emails to Outlook users.  For 
> reference, my work domain has one user (me).  I have had the account for 
> about 9 months and I have not yet sent 100 emails.  I typically send an email 
> to a single recipient, although I will occasionally CC a handful of people.
> 
>  
> 
> What I’ve tried:
> 
>  
> 
>   • I have also set up SPF, DKIM, and DMARC.  I’m *pretty sure* they’re 
> solid.  Emails still go to junk.
>   • Initially, I didn’t have anything actually at the website for my 
> domain, so I threw my executive summary into a google site.  Emails still go 
> to junk
>   • I've checked our public IP and the domain name at mxtoolbox.com – no 
> errors, but it warns that a) my DMARC policy isn’t q or r, and b) it doesn’t 
> care for my SOA
>   • I tried to get on Microsoft’s SDNS and JMRP, but I was not able.  I 
> am pretty sure I have a shared IP, but I don’t know how I would check that.  
> Microsoft also suggested I join the Return Path Safe Senders program, but I 
> am pretty sure I would need a dedicated IP for that.  In any case, I don’t 
> love the idea of paying to get whitelisted so I can send 11 emails a month.
>   • I’ve checked several sites and my domain isn’t on any blacklists.  
> However, I did register the domain through NameCheap, which is on the 
> UCEPROTECT_LVL3 list
>   • The domain is relatively new, as I said, but I don’t send any bulk 
> mail of any kind from it.  All mail is either to people I specifically know, 
> people to whom I have received a personal introduction, or people listed as 
> contacts for their organization on public websites
>   • My mail is handled by Zoho Mail, so I haven’t done anything fancy 
> with the mail server.  If there’s anything I should try, I will, but I might 
> need the instructions at a fifth-grade level
>   • I am fairly careful with my words, and the emails are appropriately 
> long, so I would be surprised if they were getting flagged for trigger words. 
>   I have tried mail-tester.com and it did not object to the body of my emails
>   • Mail-tester.com claims to test emails against SA, although I know 
> this is a contentious point around here.  I bring it up, though, because the 
> fact that my TLD is “.space” raised some flags
>   • When I have called my contacts, they have been as confused as I am 
> that they did not receive my emails
>   • Emails I send to any other domains are never a problem spam-wise
>  
> 
> Notes:
> 
>   • I do not have a list-unsubscribe header in my emails, for one because 
> I don’t have a list, and for two, because I don’t really know how.  I can add 
> one if necessary, although ideally I’d like the language to be clear that my 
> emails don’t go to a list of any kind
>   • I have a signature in my email.  It has my phone number, but no 
> address because I don’t have a physical location yet.  Some articles 
> suggested this is bad; I hate to put my home address in all my emails, but I 
> can if necessary.  It’s in my Dun and Bradstreet profile, anyway
>   • My domain contacts are anonymized, courtesy of NameCheap.  NameCheap 
> made this sound appealing, but I read somewhere that this makes you look 
> sketchy.  I could fix this, if necessary.
>  
> 
> I suspect I’ve already given you the smoking gun, but if this isn’t enough 
> information to hit on the problem, I am happy to provide more
> 
>  
> 



Re: netflix phishing emails forwarded via sendgrid

2021-02-02 Thread Anne P. Mitchell, Esq.
Does anyone have a copy of the netflix phishing that they could forward to me 
at amitch...@isipp.com, including the body of it?

TIA!

Anne

> On Feb 2, 2021, at 1:04 AM, Benny Pedersen  wrote:
> 
> On 2021-02-02 03:25, Kevin A. McGrail wrote:
>> Since it's already hitting 8.9, why do more?
> 
> too much phishing in winter half year to my taste
> 
> i just google report urls now, and still add to phishtank, hopefully phishers 
> get a real life
> 
> you can safely add 1.5 more to KAM_SENDGRID, if it continues i do it localy
> 
> no need to argue http://multirbl.valli.org/lookup/149.72.91.245.html :-)
> 
>> On 1/19/2021 9:07 PM, Benny Pedersen wrote:
>>> i have added urls to phishtank
>>> if its could be added rules to spamassassin to detect it better i can send 
>>> sample to sa pmc members
>>> X-Spam-Status: Yes, score=8.9, required=5.0, Autolearn=no 
>>> autolearn_force=no,
>>> LastExt=149.72.91.245
>>> X-Spam-Rules_score: 
>>> DATE_IN_PAST_03_06=1.076,DKIM_SIGNED=-0.1,DKIM_VALID=-0.1,
>>> DKIM_VALID_AU=-0.1,DKIM_VALID_EF=-0.1,HTML_IMAGE_ONLY_32=0.001,
>>> HTML_MESSAGE=0.1,KAM_NUMSUBJECT=0.5,KAM_REALLYHUGEIMGSRC=0.5,
>>> KAM_SENDGRID=1.5,RCVD_IN_BRUKALAI_BLACK=2,SENDGRID_REDIR=0.932,
>>> SPF_HELO_NONE=3,SPF_PASS=-0.1,TXREP=-0.187,UNPARSEABLE_RELAY=0.001
>>> mx relay is sendgrid, but enveloppe sender is not sendgrid
>>> https://phishtank.com/phish_detail.php?phish_id=6927641
>>> https://phishtank.com/phish_detail.php?phish_id=6927893



Re: Technically not spam

2020-05-29 Thread Anne P. Mitchell, Esq.



> Really? Does it specific that the user dodoesn’t have to be logged in to the 
> site?
> 
> Do you have the law handy, I'd like to add it to some boilerplate.

It was part of the FTC's 2008 update to CAN-SPAM, using their rulemaking 
authority, so it's not directly in the text of the original CAN-SPAM (which was 
brought online in 2003).  What the FTC said in that update in 2008 is:

"an e-mail recipient cannot be required to pay a fee, provide information other 
than his or her e-mail address and opt-out preferences, or take any steps other 
than sending a reply e-mail message or visiting a single Internet Web page to 
opt out of receiving future e-mail from a sender."

It's this:

"or take any steps other than sending a reply e-mail message or visiting a 
single Internet Web page to opt out of receiving future e-mail from a sender"

that creates the one-step rule.

Having to visit a page, and then enter a password, and then opt-out is 3 steps.

The somewhat plain English explanation of this and the other new 2008 
rules/clarifications is here:

https://www.ftc.gov/news-events/press-releases/2008/05/ftc-approves-new-rule-provision-under-can-spam-act

The more in-depth version is here:

https://www.ftc.gov/sites/default/files/documents/federal_register_notices/definitions-and-implementation-under-can-spam-act-16-cfr-part-316/080521canspamact.pdf

Anne

--
Anne P. Mitchell, Esq.
Dean of Cyberlaw & Cybersecurity, Lincoln Law School
CEO, SuretyMail Email Reputation Certification
Advisor, Governor's Innovation Response Team Task Force
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant, GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
Board of Directors, Denver Internet Exchange
Former Counsel: Mail Abuse Prevention System (MAPS)






Re: Technically not spam

2020-05-29 Thread Anne P. Mitchell, Esq.


> Probably not, but the user doesn't care, just wants the mail gone and to stop 
> showing up. Telling them to go to the site, jump through password recovery 
> hoop and then unsubscribe (which on some sites is quite difficult, as you 
> will be signed up for 5 or 6 different mailings, each of which you have to 
> seek out individually) is … well, not going to work with many users, 
> especially the less technical.

Not to mention that it is a violation of Federal law.  Federal law requires a 
"one-step" unsubscribe method.

Anne

--
Anne P. Mitchell, Esq.
Dean of Cyberlaw & Cybersecurity, Lincoln Law School
CEO, SuretyMail Email Reputation Certification
Advisor, Governor's Innovation Response Team Task Force
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant, GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
Board of Directors, Denver Internet Exchange
Former Counsel: Mail Abuse Prevention System (MAPS)




Re: who is IADB and why does this spam get a -3.8 score?

2019-08-08 Thread Anne P. Mitchell, Esq.
The offending sender has been terminated by the ESP.

> On Aug 7, 2019, at 3:06 PM, Anne P. Mitchell, Esq.  
> wrote:
> 
> Hi David!
> 
> We are the IADB, and if you are getting spam from an accredited IP address, 
> we definitely want to know about it.  The reason that email from that IP gets 
> that score is because it is supposed to be 100% opt-in - clearly if you 
> didn't opt in, then it's not - and so we will take the responsible party to 
> task for it, and asap.
> 
> Can you please forward a copy, with headers, directly to me, and I will 
> personally make sure that it is taken care of, and with haste.
> 
> Thank you.
> 
> Anne
> 
> Anne P. Mitchell, Attorney at Law
> CEO/President, Institute for Social Internet Public Policy
> Dean of Cybersecurity & Cyberlaw, Lincoln Law School of San Jose
> Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
> Legislative Consultant
> GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
> Board of Directors, Denver Internet Exchange
> Board of Directors, Asilomar Microcomputer Workshop
> Legal Counsel: The CyberGreen Institute
> Former Counsel: Mail Abuse Prevention System (MAPS)
> Member: California Bar Association
> 
> 
>> 
>> Why does this spam source get such a boost?
>> 
>>   -0.0 RCVD_IN_IADB_LISTEDRBL: Participates in the IADB system
>>   -0.1 RCVD_IN_IADB_SPF   RBL: IADB: Sender publishes SPF record
>>   -1.5 RCVD_IN_IADB_OPTIN RBL: IADB: All mailing list mail is opt-in
>>   -2.2 RCVD_IN_IADB_VOUCHED   RBL: ISIPP IADB lists as vouched-for sender
>>   -0.0 RCVD_IN_IADB_SENDERID  RBL: IADB: Sender publishes Sender ID record
>> 
>> In particular how can they claim "All mailing list mail is opt-in" for a 
>> message sent to a spam-trap address that has never been used in any way 
>> other than a spam-trap? (IE never used to send mail, never listed as a 
>> contact address, etc).
>> 
>> The message had a "unsubscribe" link but no "report spam" functions.
>> 
>> Why should we have to "unsubscribe" an address that was never subscribed at 
>> all?
>> (that would tend to give legitimacy to the spammer's claims that it was 
>> subscribed/opt-in ).
>> 
>> who should I report this travesty to?
>> 
>> -- 
>> Dave Funk  University of Iowa
>> College of Engineering
>> 319/335-5751   FAX: 319/384-0549   1256 Seamans Center
>> Sys_admin/Postmaster/cell_adminIowa City, IA 52242-1527
>> #include 
>> Better is not better, 'standard' is better. B{
> 



Re: who is IADB and why does this spam get a -3.8 score?

2019-08-07 Thread Anne P. Mitchell, Esq.
Hi David!

We are the IADB, and if you are getting spam from an accredited IP address, we 
definitely want to know about it.  The reason that email from that IP gets that 
score is because it is supposed to be 100% opt-in - clearly if you didn't opt 
in, then it's not - and so we will take the responsible party to task for it, 
and asap.

Can you please forward a copy, with headers, directly to me, and I will 
personally make sure that it is taken care of, and with haste.

Thank you.

Anne

Anne P. Mitchell, Attorney at Law
CEO/President, Institute for Social Internet Public Policy
Dean of Cybersecurity & Cyberlaw, Lincoln Law School of San Jose
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
Board of Directors, Denver Internet Exchange
Board of Directors, Asilomar Microcomputer Workshop
Legal Counsel: The CyberGreen Institute
Former Counsel: Mail Abuse Prevention System (MAPS)
Member: California Bar Association


> On Aug 7, 2019, at 2:57 PM, David B Funk  wrote:
> 
> This afternoon I found a spam in one of my spam-traps that was sent via 
> constantcontact.com and got a whopping -3.8 from IADB rules.
> 
> Why does this spam source get such a boost?
> 
>-0.0 RCVD_IN_IADB_LISTEDRBL: Participates in the IADB system
>-0.1 RCVD_IN_IADB_SPF   RBL: IADB: Sender publishes SPF record
>-1.5 RCVD_IN_IADB_OPTIN RBL: IADB: All mailing list mail is opt-in
>-2.2 RCVD_IN_IADB_VOUCHED   RBL: ISIPP IADB lists as vouched-for sender
>-0.0 RCVD_IN_IADB_SENDERID  RBL: IADB: Sender publishes Sender ID record
> 
> In particular how can they claim "All mailing list mail is opt-in" for a 
> message sent to a spam-trap address that has never been used in any way other 
> than a spam-trap? (IE never used to send mail, never listed as a contact 
> address, etc).
> 
> The message had a "unsubscribe" link but no "report spam" functions.
> 
> Why should we have to "unsubscribe" an address that was never subscribed at 
> all?
> (that would tend to give legitimacy to the spammer's claims that it was 
> subscribed/opt-in ).
> 
> who should I report this travesty to?
> 
> -- 
> Dave Funk  University of Iowa
> College of Engineering
> 319/335-5751   FAX: 319/384-0549   1256 Seamans Center
> Sys_admin/Postmaster/cell_adminIowa City, IA 52242-1527
> #include 
> Better is not better, 'standard' is better. B{



Re: semi-OT - reporting an organization that ignores unsubscribe requests

2018-11-25 Thread Anne P. Mitchell, Esq.



> 
> I don't want to weigh in on the perceived worth of your signature, but
> are you aware of the signature convention that has been around for
> decades? It is mentioned in RFC 3676 and many other places:
> 
>  There is a long-standing convention in Usenet news which also commonly
>  appears in Internet mail of using "-- " as the separator line between
>  the body and the signature of a message.
> 
>  (https://tools.ietf.org/html/rfc3676#section-4.3)
> 
> If you prefix your signature with DASH DASH SPACE, smart MUAs will
> either show the signature in muted colours, in a collapsed state, or by
> other means of making it less intrusive.

That's odd...until you mentioned it I wasn't aware that my MUA was *not* 
including that!...let me see if I can figure out why it isn't.  Thank you!

Anne

(suppressing .sig for now)

Re: semi-OT - reporting an organization that ignores unsubscribe requests

2018-11-25 Thread Anne P. Mitchell, Esq.



> On Nov 24, 2018, at 4:25 PM, @lbutlr  wrote:
> 
> This is a very excessive signature block. I’m glad your proud of your resume, 
> but inflicting itnon a mailing list with every post is a bit much. 

It's not a matter of pride, and I generally don't disagree with you...however 
when discussing things actually having to do with the law, I have found that 
establishing my expertise and authority up front tends to ward off lengthy 
discussions that take up way more mailing list bandwidth than the signature.

Much like this email, really.

Anne

Anne P. Mitchell, 
Attorney at Law
GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Board of Directors, Denver Internet Exchange
Board of Directors, Asilomar Microcomputer Workshop
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
California Bar Association
Cal. Bar Cyberspace Law Committee
Colorado Cyber Committee
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop





Re: semi-OT - reporting an organization that ignores unsubscribe requests

2018-11-21 Thread Anne P. Mitchell, Esq.



> On Nov 21, 2018, at 12:03 PM, Bill Cole 
>  wrote:
> 
> On 21 Nov 2018, at 13:03, Anne P. Mitchell, Esq. wrote:
> 
>> Except for the private right of action provided in GDPR, and small claims 
>> court in the U.S.
> 
> Are you saying an EU law can create an actionable civil tort claim in a US 
> state small claims court for actions which are not illegal under any US state 
> or federal law?

No, I'm saying that anybody can sue anybody for anything in the U.S., and it's 
extremely easy to file an action in small claims court.  It wouldn't even have 
to be, technically, 'under' GDPR (as you mention, there is always tort) - but 
GDPR would be the hook that they would use, and the authority (note I said 
authority, not law) they would cite.

That said, I think it's much more likely that the lawsuits already filed 
against Google and Facebook by Max Schrems will be ones to test the 
jurisdiction/enforcement issues.

Anne

Anne P. Mitchell, 
Attorney at Law
GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Board of Directors, Denver Internet Exchange
Board of Directors, Asilomar Microcomputer Workshop
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
California Bar Association
Cal. Bar Cyberspace Law Committee
Colorado Cyber Committee
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop




Re: semi-OT - reporting an organization that ignores unsubscribe requests

2018-11-21 Thread Anne P. Mitchell, Esq.
P.S.  I should have added: the whole jurisdiction issue is, clinically 
speaking, one of the most interesting parts of GDPR. I've never seen a law that 
so broadly asserted that the country or union from which the law was 
promulgated will enforce it anywhere and everywhere - it's pretty damned gutsy. 
 It will almost certainly be sorted out through lawsuits, and that will 
definitely be popcorn time.


> On Nov 21, 2018, at 11:03 AM, Anne P. Mitchell, Esq.  
> wrote:
> 
> 
> 
>> On Nov 21, 2018, at 8:48 AM, Bill Cole 
>>  wrote:
>> 
>> There is no reason for anyone without a commercial presence in the EU or CH 
>> to be concerned with GDPR.
> 
> Except for the private right of action provided in GDPR, and small claims 
> court in the U.S.  
> 
> And, for entities that spam enough people "in the EU" (for our 
> analysis/explanation of that, along with why U.S. companies should comply 
> with GDPR, see here: 
> https://www.isipp.com/resources/how-email-marketing-must-comply-with-the-eu-general-data-protection-regulation-gdpr/
>   NB:  GDPR does not state anywhere that it applies to EU residents or 
> citizens, only the vague and ambiguous "in the EU") the language in GDPR that 
> states they will go after anyone, anywhere in the world.
> 
> Anne
> 
> Anne P. Mitchell, 
> Attorney at Law
> GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
> Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
> Legislative Consultant
> CEO/President, Institute for Social Internet Public Policy
> Board of Directors, Denver Internet Exchange
> Board of Directors, Asilomar Microcomputer Workshop
> Legal Counsel: The CyberGreen Institute
> Legal Counsel: The Earth Law Center
> California Bar Association
> Cal. Bar Cyberspace Law Committee
> Colorado Cyber Committee
> Ret. Professor of Law, Lincoln Law School of San Jose
> Ret. Chair, Asilomar Microcomputer Workshop
> 
> 
> 
> 



Re: semi-OT - reporting an organization that ignores unsubscribe requests

2018-11-21 Thread Anne P. Mitchell, Esq.



> On Nov 21, 2018, at 8:48 AM, Bill Cole 
>  wrote:
> 
> There is no reason for anyone without a commercial presence in the EU or CH 
> to be concerned with GDPR.

Except for the private right of action provided in GDPR, and small claims court 
in the U.S.  

And, for entities that spam enough people "in the EU" (for our 
analysis/explanation of that, along with why U.S. companies should comply with 
GDPR, see here: 
https://www.isipp.com/resources/how-email-marketing-must-comply-with-the-eu-general-data-protection-regulation-gdpr/
  NB:  GDPR does not state anywhere that it applies to EU residents or 
citizens, only the vague and ambiguous "in the EU") the language in GDPR that 
states they will go after anyone, anywhere in the world.

Anne

Anne P. Mitchell, 
Attorney at Law
GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Board of Directors, Denver Internet Exchange
Board of Directors, Asilomar Microcomputer Workshop
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
California Bar Association
Cal. Bar Cyberspace Law Committee
Colorado Cyber Committee
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop






Re: semi-OT - reporting an organization that ignores unsubscribe requests

2018-11-20 Thread Anne P. Mitchell, Esq.



> The email address is an address, part of your personally identifiable data. 
> If an identifiable entity in the US sends mass mail to European addresses, 
> then they must have a representative in Europe and comply with the GDPR. 

I somehow missed that John is in the U.K., and actually re-reading his email 
suggests that he may be in Canada ("hoses me off" ;-) )...  John, if you are in 
Canada than this may fall under CASL, in which case you can report the email 
here:

http://fightspam.gc.ca/eic/site/030.nsf/eng/h_00017.html

If you are, in fact, in the EU, then by all means I'd go the route of invoking 
GDPR.  Many (if not most..sigh) entities in the U.S. believe that they don't 
have to worry or care about GDPR..however the language in GDPR that says, in 
essence, "we will go after anybody anywhere in the world who violates GDPR" 
coupled with the private right of action suggests that you'd at least have a 
shot.  The reason that political spam is exempted in the U.S. is because of the 
1st Amendment..which of course does not apply outside the U.S.. ;-)

Anne

Anne P. Mitchell, 
Attorney at Law
GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Board of Directors, Denver Internet Exchange
Board of Directors, Asilomar Microcomputer Workshop
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
California Bar Association
Cal. Bar Cyberspace Law Committee
Colorado Cyber Committee
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop





> 
> 
> On Tue, Nov 20, 2018 at 17:03, John Hardin  wrote:
>> On Tue, 20 Nov 2018, Rupert Gallagher wrote:
>> 
>> > Yes, if you are European, and might get some money as compensation.
>> 
>> From a US political advocacy group which has no commercial presence in EU?
>> How does GDPR apply in that situation?
>> 
>> > On Mon, Nov 19, 2018 at 04:19, Joe Acquisto-j4  
>> > wrote:
>> >
>> >> Gents,
>> >>
>> >> I somehow became subscribed to a list, political in nature, in whose mail 
>> >> I have no interest. This is a legitimate AFAIK, US organization.
>> >>
>> >> Thus far, several uses of their unsubscribe link had not provided relief. 
>> >> Direct email to the founder and operations manager seem to have been 
>> >> ignored as well.
>> >>
>> >> While I can just dump their mail, it offends my finely hones sense of 
>> >> propriety, justice and my all around good nature. Besides, it hoses me 
>> >> off.
>> >>
>> >> So, is there some "authority" to which I can report these a**holes? that 
>> >> might have an effect?
>> 
>> --
>> John Hardin KA7OHZ http://www.impsec.org/~jhardin/
>> jhar...@impsec.org FALaholic #11174 pgpk -a jhar...@impsec.org
>> key: 0xB8732E79 -- 2D8C 34F4 6411 F507 136C AF76 D822 E6E6 B873 2E79
>> ---
>> The world has enough Mouse Clicking System Engineers.
>> -- Dave Pooser
>> ---
>> 600 days since the first commercial re-flight of an orbital booster (SpaceX)
> 
> 



Re: semi-OT - reporting an organization that ignores unsubscribe requests

2018-11-20 Thread Anne P. Mitchell, Esq.



> 
> Gents,  

Ahem.  ;-)


> 
> I somehow became subscribed to a list, political in nature, in whose mail I 
> have no interest.  This is a legitimate AFAIK, US organization.  
> 
> Thus far, several uses of their unsubscribe link had not provided relief.  
> Direct email to the founder and operations manager seem to have been ignored 
> as well.
> 
> While I can just dump their mail, it offends my finely hones sense of 
> propriety, justice and my all around good nature.  Besides, it hoses me off.
> 
> So, is there some "authority" to which I can report these a**holes? that 
> might have an effect?

Speaking as someone who actually wrote part of the U.S. anti-spam law (of which 
I'm the first to say that it is pathetic and anemic (except of course, the part 
that I wrote ;-) )...I can say categorically that political email is exempt 
from most Federal law relating to email, email marketing, etc.. 

But THAT said, a word to their provider can (and sometimes does) still have the 
desired (individual) effect, because providers care about their IP space 
reputation (more so than most political campaigns).

Anne

Anne P. Mitchell, 
Attorney at Law
GDPR, CCPA (CA) & CCDPA (CO) Compliance Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Board of Directors, Denver Internet Exchange
Board of Directors, Asilomar Microcomputer Workshop
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
California Bar Association
Cal. Bar Cyberspace Law Committee
Colorado Cyber Committee
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop






Re: Bayes overtraining

2018-08-24 Thread Anne P. Mitchell, Esq.



 
> 
>>> There are spams hitting negative scoring rules e.g.  MAILING_LIST_MULTI,
>>> RCVD_IN_RP_*, RCVD_IN_IADB_* and they are constantly trained as ham.

Just a reminder, if you ever receive spam which is tagged as RCVD_IN_IADB (or 
*any* flavour of IADB tag) *please* forward it to me personally and I will 
personally make sure that whoever it is sending it is soundly whacked.

We do *not* have a sense of humour about anyone sending anything that is not 
100% true opt-in (if not confirmed opt-in) - and we do *not* certify anyone who 
is doing anything less - and if we find that someone's practices have slipped 
and they are being sloppy with permission, we fire them.  Our definition of 
spam is the definition that Paul (Vixie) and I put forward years ago:

“An electronic message is “spam” IF: (1) the recipient’s personal identity and 
context are
irrelevant because the message is equally applicable to many other potential 
recipients;
AND (2) the recipient has not verifiably granted deliberate, explicit, and 
still-revocable
permission for it to be sent; AND (3) the transmission and reception of the 
message
appears to the recipient to give a disproportionate benefit to the sender.”

Anything less is grounds for immediate termination.

So, again, if you ever find anything that triggers an IADB rule that is not 
something for which you/your user affirmatively opted in, we want to know about 
it.

The buck stops right here:

Anne

Anne P. Mitchell, 
Attorney at Law
CEO/President, 
SuretyMail Email Reputation Certification and Inbox Delivery Assistance
GDPR & CCPA Compliance Consultant
GDPR & CCPA Compliance Certification
http://www.SuretyMail.com/
http://www.SuretyMail.eu/

Attorney at Law / Legislative Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Author: The Email Deliverability Handbook
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
Member, California Bar Cyberspace Law Committee
Member, Colorado Cybersecurity Consortium
Member, Board of Directors, Asilomar Microcomputer Workshop
Former Chair, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose




Re: IADB whitelist - again

2018-03-01 Thread Anne P. Mitchell Esq.
 one of the few aspects of CAN-SPAM 
with teeth - it's the vendor liability section, which actually means the "you 
don't get to run an affiliate program and look the other way while you profit 
from your affiliates spamming - we're looking at you Gevalia" section." (*For 
those of you who are also law/policy wonks, text of Section 6 available upon 
request. :-) )

My point is - I am, and we are, about as rabidly anti-spam as they come.  And 
that's why we have the scores that we do.  Because we worked hard to earn that 
trust, we are trustworthy, approachable, transparent and, most importantly, on 
the right side of the fight.

Anne

Anne P. Mitchell, 
Attorney at Law
CEO/President, 
SuretyMail Email Reputation Certification
http://www.SuretyMail.com/
http://www.SuretyMail.eu/

Attorney at Law / Legislative Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Author: The Email Deliverability Handbook
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
Member, California Bar Cyberspace Law Committee
Member, Colorado Cybersecurity Consortium
Member, Board of Directors, Asilomar Microcomputer Workshop
Member, Advisory Board, Cause for Awareness
Member, Elevations Credit Union Member Council
Former Chair, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose

Available for consultations by special arrangement.
amitch...@isipp.com | @AnnePMitchell
Facebook/AnnePMitchell  | LinkedIn/in/annemitchell





Re: Email filtering theory and the definition of spam

2018-02-06 Thread Anne P. Mitchell Esq.

 
> 
> I know the definition of spam is very subjective and dependent on your 
> particular the mail flow along with the expectations of the recipients.
> 

Back when I was in-house counsel at MAPS, Paul (Vixie) and I came up with this 
definition of spam:

“An electronic message is “spam” IF: (1) the recipient’s personal identity and 
context are
irrelevant because the message is equally applicable to many other potential 
recipients;
AND (2) the recipient has not verifiably granted deliberate, explicit, and 
still-revocable
permission for it to be sent; AND (3) the transmission and reception of the 
message
appears to the recipient to give a disproportionate benefit to the sender.”

I think that it still holds up. 

Anne

Anne P. Mitchell, 
Attorney at Law
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
Member, Cal. Bar Cyberspace Law Committee
Member, Colorado Cyber Committee
Member, Elevations Credit Union Member Council
Member, Board of Directors, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop



Re: Tone of emails with subject: 'hey'

2018-02-06 Thread Anne P. Mitchell Esq.

Ironically, Gmail's spam filters have filtered every single one of the emails 
in this thread. :-\

Anne

Anne P. Mitchell, 
Attorney at Law
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
Member, Cal. Bar Cyberspace Law Committee
Member, Colorado Cyber Committee
Member, Elevations Credit Union Member Council
Member, Board of Directors, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop



Re: IADB whitelist

2017-12-26 Thread Anne P. Mitchell Esq.

 
> 
> My sense is that ESPs engage ISIPP thinking they are getting an advocate and 
> ambassador to mailbox providers when in fact they get a teacher/evangelist 
> for sender best practices.

ITYM 'schooled in best practices. ;-) ;-)

Anne P. Mitchell, 
Attorney at Law
CEO/President, 
SuretyMail Email Reputation Certification and Inbox Delivery Assistance
http://www.SuretyMail.com/
http://www.SuretyMail.eu/

Attorney at Law / Legislative Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Author: The Email Deliverability Handbook
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
Member, California Bar Cyberspace Law Committee
Member, Colorado Cybersecurity Consortium
Member, Board of Directors, Asilomar Microcomputer Workshop
Member, Advisory Board, Cause for Awareness
Member, Elevations Credit Union Member Council
Former Chair, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose

Available for consultations by special arrangement.
amitch...@isipp.com | @AnnePMitchell
Facebook/AnnePMitchell  | LinkedIn/in/annemitchell

Re: IADB whitelist

2017-12-26 Thread Anne P. Mitchell Esq.

 
> 
> What do you call *verified* opt-in (what the marketers call "double opt-in"), 
> where the recipient needs to comfirm that they gave permission for contact 
> via that email address before receiving any content, in order to avoid 
> unwanted third-party subscriptions?

Confirmed opt-in, which is what it was called back at MAPS and when we launched 
SuretyMail.

Even there we have granular breakdowns, such as:

127.3.100.8 All mailing list mail is at least opt-in, and has a confirmed 
(double) opt-in mechanism available, used less than 50% of the time
127.3.100.9 All mailing list mail is at least opt-in, and has a confirmed 
(double) opt-in mechanism available, used more than 50% of the time
127.3.100.10All mailing list mail is confirmed (double) opt-in

---

(Note that we include the 'double' term (even though I feel I have to shower 
after typing it) because that is the vernacular with which more senders are 
familiar.

Also note that there are data response codes that we would, in fact, almost 
never (if ever) use, but which are *great* for applicant screening - so for 
example if an applicant says:

"Accepts unverified sign-ups such as through web page" (which is one of our 
codes)

...they are never actually going to get certified (unless we can educate them 
and they actually change their wicked ways).


You can see the full list of codes here:

http://www.isipp.com/email-accreditation/about-the-codes/list-of-codes/

Anne

Anne P. Mitchell, 
Attorney at Law
CEO/President, 
SuretyMail Email Reputation Certification and Inbox Delivery Assistance
http://www.SuretyMail.com/
http://www.SuretyMail.eu/

Attorney at Law / Legislative Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Author: The Email Deliverability Handbook
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
Member, California Bar Cyberspace Law Committee
Member, Colorado Cybersecurity Consortium
Member, Board of Directors, Asilomar Microcomputer Workshop
Member, Advisory Board, Cause for Awareness
Member, Elevations Credit Union Member Council
Former Chair, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose

Available for consultations by special arrangement.
amitch...@isipp.com | @AnnePMitchell
Facebook/AnnePMitchell  | LinkedIn/in/annemitchell



Re: IADB whitelist

2017-12-26 Thread Anne P. Mitchell Esq.

 
> 
> 'magically' re-subscribe after a while, or simply get around rules by 
> creating a new list and re-subscribing everybody who unsubscribed.

Just so you know, that behavior is specifically made illegal by CAN-SPAM.  And 
Sebastian, I see that you are in the UK, which already has tighter laws.

Anne

Anne P. Mitchell, 
Attorney at Law
CEO/President, 
SuretyMail Email Reputation Certification and Inbox Delivery Assistance
http://www.SuretyMail.com/
http://www.SuretyMail.eu/

Attorney at Law / Legislative Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Author: The Email Deliverability Handbook
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
Member, California Bar Cyberspace Law Committee
Member, Colorado Cybersecurity Consortium
Member, Board of Directors, Asilomar Microcomputer Workshop
Member, Advisory Board, Cause for Awareness
Member, Elevations Credit Union Member Council
Former Chair, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose

Available for consultations by special arrangement.
amitch...@isipp.com | @AnnePMitchell
Facebook/AnnePMitchell  | LinkedIn/in/annemitchell

Re: IADB whitelist

2017-12-26 Thread Anne P. Mitchell Esq.
Bill, thank you for this excellent explanation, and for the kind words!

For those of you who don't know us, or me, I came out of MAPS;  I was in-house 
counsel for MAPS during the first rash of lawsuits against MAPS brought by 
spammers.  To say that I am rabidly anti-spam would be an understatement.

ISIPP, and our SuretyMail service, were founded by me a year and a bit after I 
left MAPS.  As such, our priority has always been, and remains, first and 
foremost, to the *receivers* - ISPs, spam filters, and any receiver who is 
using our data/zones.

It is true that the senders are our paying customers, however by design the 
amount of monies we receive from any given customer is small enough that the 
pleasure of whacking a spammer far outweighs any downside of giving a paying 
customer the boot if they are not doing The Right Thing.  Plus, we have a very 
extensive background check that we put a potential customer (sender) through 
before we will certify them.  We reject plenty of applicants.

> However, the different responses from IADB are VERY nuanced and the two 
> strongest rules you listed (RCVD_IN_IADB_OPTIN and RCVD_IN_IADB_VOUCHED) are 
> essentially "good intentions" markers.
> Due to unfortunate terminology choices by ISIPP and a willingness to engage 
> in nuance and estimate intentions, those aren't really as worthwhile as they 
> might seem. 

Hey Bill - can you please elaborate on the terminology choices which you see as 
unfortunate? We are *always* open to input.  Where we say "opt-in" we mean 
exactly that - single opt-in;  if someone didn't ask for the email not only 
would we call that "opt-out", but we would not certify that sender's email.  
And if one of our senders is sending spam where they claim that all of their 
mailings are 100% opt-in (at least) we want to know, because...whack!

Seriously, we are always open to feedback, and if a change in terminology is 
warranted we have no problem doing that (we also are happy to create a custom 
zone based on whatever the receiver wants for those who would like zones with 
highly specific profiles of the IPs therein - some receivers do that because 
they can't take advantage of the granularity of the data in our zones (although 
that is not the case for SA...in fact our data response codes were 
*specifically* created for SA because SA *can* take advantage of that level of 
granularity)).

Anne

Anne P. Mitchell, 
Attorney at Law
CEO/President, 
SuretyMail Email Reputation Certification and Inbox Delivery Assistance
http://www.SuretyMail.com/
http://www.SuretyMail.eu/

Attorney at Law / Legislative Consultant
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Author: The Email Deliverability Handbook
Legal Counsel: The CyberGreen Institute
Legal Counsel: The Earth Law Center
Member, California Bar Cyberspace Law Committee
Member, Colorado Cybersecurity Consortium
Member, Board of Directors, Asilomar Microcomputer Workshop
Member, Advisory Board, Cause for Awareness
Member, Elevations Credit Union Member Council
Former Chair, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose

Available for consultations by special arrangement.
amitch...@isipp.com | @AnnePMitchell
Facebook/AnnePMitchell  | LinkedIn/in/annemitchell

Response from ISIPP (was Re: ISIPP - Re: bb.barracudacentral.org)

2017-11-15 Thread Anne P. Mitchell Esq.
Hi Guys!

This thread was only just brought to our attention, and the thread is now 
several levels deep and a bit old, so if you can help me out with letting me 
know what the outstanding issues are, I'd really appreciate it.  

As best as I can tell from reading through the thread online, there are two 
questions:

1.  Something to do with our zones not responding (?) and 

2.  Something which is causing questions regarding the IADB rules, however I 
can't find what triggered it or the actual question.

We did have an issue with our master zone server a few weeks ago, however to 
the best of my knowledge it was a) resolved quickly, and b) hasn't happened 
again.  We also have several secondaries on line so, at least in theory, any 
lookups to the IADB should have been serviced as usual.  Are folks still seeing 
issues with that?

As for #2, I'm here to answer any questions and to address any concerns you may 
have.  We treasure (seriously) our relationship with SA - we developed the IADB 
response codes with Craig Hughes *specifically* so that SA could take advantage 
of them, and the IADB generally, so if there are issues now, we definitely want 
to know and get them addressed.  I should also remind folks, in case 
institutional memory from back then is no longer here, that we are happy to 
create any new data response code that would be useful for SA. (For example, 
the "127.3.100.100The only email which comes from this IP address is 
mailing list email, and that mailing list email is entirely confirmed (double) 
opt-in" data response code was created at the request of another spam 
filtering/reporting system, and they make a point of looking for it in our 
zones now.)

As you may know, we consider our first duty to be to the *receiving* community 
(for those who don't know, I came to this by way of being in-house counsel for 
Paul Vixie and MAPS, so I am seriously anti-spam, and part of the receiving 
community); but we can't address any issues if they aren't brought to our 
attention.  That just happened, and here I am! :-)

Anne

Anne P. Mitchell, 
Attorney at Law
CEO/President, Institute for Social Internet Public Policy (ISIPP)
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
Legal Counsel: The CyberGreen Institute
Member, Cal. Bar Cyberspace Law Committee
Member, Colorado Cyber Committee
Member, Elevations Credit Union Member Council
Member, Board of Directors, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop



On 2017-09-18 08:12, "Kevin A. McGrail"  wrote: 
> On 9/16/2017 4:36 PM, Chris wrote:> 
> > I'm also seeing issues with ISIPP which is in 20_dnsbl_tests.cf. I've> 
> > attached the message I sent them as well as their reply. Another issue> 
> > I noticed with ISIPP is> 
> >> 
> > Sep 16 12:09:38 localhost named[1284]: host unreachable resolving> 
> > 'ns1.ns.isipp.com/A/IN': 67.227.190.38#53> 
> > Sep 16 12:09:38 localhost named[1284]: host unreachable resolving> 
> > 'ns2.ns.isipp.com/A/IN': 67.227.190.38#53> 
> >> 
> > My network is up> 
> >> 
> > chris@localhost:~$ time host isipp.com> 
> > isipp.com has address 67.227.187.192> 
> > isipp.com mail is handled by 5 smtp.secureserver.net.> 
> > isipp.com mail is handled by 0 concerto.isipp.com.> 
> > isipp.com mail is handled by 10 mailstore1.secureserver.net.> 
> >> 
> > real††† 0m0.866s> 
> > user††† 0m0.008s> 
> > sys††† 0m0.004s> 
> > chris@localhost:~$ time host isipp.com> 
> > isipp.com has address 67.227.187.192> 
> > isipp.com mail is handled by 0 concerto.isipp.com.> 
> > isipp.com mail is handled by 10 mailstore1.secureserver.net.> 
> > isipp.com mail is handled by 5 smtp.secureserver.net.> 
> >> 
> > real††† 0m0.010s> 
> > user††† 0m0.008s> 
> > sys††† 0m0.000s> 
> >> 
> > Problem, or something I shouldn't concern myself about?> 
> 
> Good question.† Perhaps another rate-limit issue or they block dynamic IPs.> 
> 
> I took this off-list by accident but Chris has low volume and uses a > 
> Dynamic IP.† I wonder if ISIPP is similar to barracuda in that it should > 
> be considered for removal from the default rules. Anyone have any feedback?> 
> 
> regards,> 
> KAM> 
> 

MailChimp Update (Was Re: MailChimp with link to javascript/zip malware)

2017-10-20 Thread Anne P. Mitchell Esq.
MailChimp has said that they believe that they have terminated all accounts 
that were responsible for this.  BUT, they say, this is a group that keeps 
cropping up (think whack-a-mole), so to please report any more of these that 
anyone receives.

Anne

Anne P. Mitchell, 
Attorney at Law
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Legal Counsel: The CyberGreen Institute
Member, Cal. Bar Cyberspace Law Committee
Member, Colorado Cyber Committee
Member, Elevations Credit Union Member Council
Member, Board of Directors, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop



Re: MailChimp with link to javascript/zip malware

2017-10-20 Thread Anne P. Mitchell Esq.
Sorry for top-posting, but just to let folks know, our contact has just let me 
know that he is on this; I'll report back with anything I hear that I can share.

Anne
 
> 
> Hi,
> 
>>> Another email from a whitelisted mailchimp address that contains malware.
>>> 
>>> https://pastebin.com/ay83iWjC
>>> 
>>> It's also not tagged when not whitelisted, and I hoped someone had
>>> some ideas on what further can be done to block it.
>>> 
>>> Complicating things, it's in Italian.
>>> 
>>> I've reported it to MailChimp and also removed mailchimp (mcdlv.net
>>> and rsgsv.net) from the local whitelist.
>> 
>> Alex, may I share this, confidentially and directly, with our abuse czar 
>> contact at Mailchimp?
> 
> Yes, sure, feel free to send them the pastebin.com link above, or
> contact me directly for more details and I'd be happy to help.
> 
>> And if so, can you please give me the spammer's from address?
> 
> Yes, it's listed in the pastebin post above as i...@scria.org.au.
> 
> Thanks, Anne, it's good to have you on this list.
> 
> Antony Stone wrote:
>> I'm intrigued as to what the "Esq." in your From address indicates?
> 
> In the US, it means she's an attorney.
> 
> Thanks,
> Alex




Re: Off-topic, was: [Re: MailChimp with link to javascript/zip malware]

2017-10-20 Thread Anne P. Mitchell Esq.

 
> 
> On Friday 20 October 2017 at 19:29:31, Anne P. Mitchell Esq. wrote:
> 
>> Anne P. Mitchell,
>> Attorney at Law
> 
> I'm intrigued as to what the "Esq." in your From address indicates?
> 
> Please feel free to reply offlist if appropriate.

In the U.S., Esq. (short for 'Esquire') means specifically a person who has 
been admitted to the practice of law and who is permitted to represent clients 
(as compared to having completed law school but not being admitted to practice 
law - in which case the person can/will put "J.D." (for juris doctor) after 
their name). That said, there are attorneys who are admitted to practice law, 
and who still use J.D., so you can't really be sure whether someone with J.D. 
after their name is admitted to practice law or not, while Esq. denotes 
definitively that the person is allowed to practice and represent clients. :-)

Anne

Anne P. Mitchell, 
Attorney at Law
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Legal Counsel: The CyberGreen Institute
Member, Cal. Bar Cyberspace Law Committee
Member, Colorado Cyber Committee
Member, Elevations Credit Union Member Council
Member, Board of Directors, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop





Re: MailChimp with link to javascript/zip malware

2017-10-20 Thread Anne P. Mitchell Esq.

 
> 
> Hi,
> 
> Another email from a whitelisted mailchimp address that contains malware.
> 
> https://pastebin.com/ay83iWjC
> 
> It's also not tagged when not whitelisted, and I hoped someone had
> some ideas on what further can be done to block it.
> 
> Complicating things, it's in Italian.
> 
> I've reported it to MailChimp and also removed mailchimp (mcdlv.net
> and rsgsv.net) from the local whitelist.

Alex, may I share this, confidentially and directly, with our abuse czar 
contact at Mailchimp?

And if so, can you please give me the spammer's from address?

Anne

Anne P. Mitchell, 
Attorney at Law
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy
Legal Counsel: The CyberGreen Institute
Member, Cal. Bar Cyberspace Law Committee
Member, Colorado Cyber Committee
Member, Elevations Credit Union Member Council
Member, Board of Directors, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop



Re: ISIPP - Re: bb.barracudacentral.org

2017-09-21 Thread Anne P. Mitchell Esq.
On 9/16/2017 4:36 PM, Chris wrote: 

>  I'm also seeing issues with ISIPP which is in 20_dnsbl_tests.cf. I've  
> attached the message I sent them as well as their reply. Another issue  I 
> noticed with ISIPP is Sep 16 12:09:38 localhost named[1284]: host unreachable 
> resolving  'ns1.ns.isipp.com/A/IN': 67.227.190.38#53  Sep 16 12:09:38 
> localhost named[1284]: host unreachable resolving  'ns2.ns.isipp.com/A/IN': 
> 67.227.190.38#53 

I apologize profusely for this... we (fairly) recently switched our colo and 
while everything was running as it should have been when we set up, it wasn't 
until Chris contacted us directly that we were aware that this issue had raised 
its head.  To the best of my knowledge this has been fixed - *please* let me 
know if it has not (or, indeed, if anyone ever has any other problems, or even 
just questions!)

To address another question, we do not distinguish between queries from static 
versus dynamic IPs in terms of who can query our zones.

As for whether the ISIPP rules should remain in the default ruleset:

When we first designed our service - which despite that senders are our 
customers, was created *for receivers* (remember that I came from MAPS - we 
*love* taking down spammers), we took great pains to ensure that our data 
response codes in our zones were easy for SA to use - in fact Craig Hughes and 
I sat down together and architected it specifically with SA in mind.  I knew 
that our design would be copied (and indeed it was by the other email sender 
certification company) and we didn't really care that it would be copied, 
because it meant more spam being able to be caught, with fewer false positives, 
which, at the end of the day, is what everybody (other than spammers) wants.

Obviously I think it would be a shame if a system that was specifically 
designed with SA in mind was no longer included in the default SA rules;  if 
there is tweaking that needs to be done - new codes created, or heck, even a 
new SA-specific zone created, we'd be more than happy to do that - that's 
*always* been how we do things - whatever makes it easiest for the *receiving* 
community, with whom, at the end of the day, our allegiance lays. ;-)

Anne

Anne P. Mitchell, 
Attorney at Law
Author: Section 6 of the CAN-SPAM Act of 2003 (the Federal anti-spam law)
Legislative Consultant
CEO/President, Institute for Social Internet Public Policy (ISIPP)
Legal Counsel: The CyberGreen Institute
Member, Cal. Bar Cyberspace Law Committee
Member, Colorado Cyber Committee
Member, Elevations Credit Union Member Council
Member, Board of Directors, Asilomar Microcomputer Workshop
Ret. Professor of Law, Lincoln Law School of San Jose
Ret. Chair, Asilomar Microcomputer Workshop



what happened to DATE_IN_PAST_48_96 ??

2007-06-18 Thread Anne

Hi,

DATE_IN_PAST_48_96 was taken out since 3.2.x. Why??
What happens with spam between 48 and 96 hours in the past?

thanks.
Anne




Re: optimization failing--fixed

2006-01-13 Thread Anne Ramey



Anne Ramey wrote:
I'm installed SA 3.1 with Amavisd-new and postfix 2.2.5 on fedora core 3 
and am having serious mail slowdowns, as much as and hour.  I've figure 
out it's SA because the SA check as taking 8-12 seconds, which was about 
75%+ of the processing. I've been trying to sort through my rulesets to 
see which one might be causing the problem with no luck.  I went ahead 
and removed all the custom rulesets and now it's soo much worse.  Now 
the SA check is taking 45 seconds (99%)!  please help.  Why would it 
take longer with fewer rulesets?  The machine load is back down, but I 
think this will slow mail down further.  I'm at a loss.  What else can I 
do to optimize the performace?


Thanks


Put /var/amavis/tmp and /var/amavis/.spamassassin on tmpfs.  All better now.

Thanks,
Anne


Re: optimization failing

2006-01-13 Thread Anne Ramey


Anne Ramey wrote:



Loren Wilton wrote:

Basically only two possibilities: you're thrashing the poor box to 
death by
running out of memory, or network tests are taking an age.  Or maybe 
both.


ok, I had a pyzor test timing out, but I've removed that, and it's still 
taking 6-15 seconds for the SA check.
I'm quite sure it's not the fault of the network tests, or at least not 
only that.  Here are the results from time spamassassin on the same 
message (all 4 times):

without network checks:
real0m5.968s
user0m1.400s
sys 0m0.170s

real0m32.084s
user0m1.431s
sys 0m0.183s

Whith network checks:
real0m11.509s
user0m1.481s
sys 0m0.214s

real0m21.296s
user0m1.527s
sys 0m0.201s


How many children?  


I've tried 8, 10, and 12 children with no noticable difference.

What load average?
load stays around 10
How much memory on the machine?  How

much free memory? 


my memory looks like this:
# free -m
 total   used   free sharedbuffers cached
Mem:  2007   1807200  0 23292
-/+ buffers/cache:   1491516
Swap: 2000 17   1982
`
 Do you have a local caching DNS for the various RBL


checks?


not yet, the DNS server is just one hop.

Anne



Loren


Re: optimization failing

2006-01-13 Thread Anne Ramey



Loren Wilton wrote:

Basically only two possibilities: you're thrashing the poor box to death by
running out of memory, or network tests are taking an age.  Or maybe both.

ok, I had a pyzor test timing out, but I've removed that, and it's still 
taking 6-15 seconds for the SA check.


How many children?  

I've tried 8, 10, and 12 children with no noticable difference.

What load average?
load stays around 10
How much memory on the machine?  How
much free memory? 

my memory looks like this:
# free -m
 total   used   free sharedbuffers cached
Mem:  2007   1807200  0 23292
-/+ buffers/cache:   1491516
Swap: 2000 17   1982
`
 Do you have a local caching DNS for the various RBL

checks?

not yet, the DNS server is just one hop.

Anne


Loren


optimization failing

2006-01-12 Thread Anne Ramey
I'm installed SA 3.1 with Amavisd-new and postfix 2.2.5 on fedora core 3 
and am having serious mail slowdowns, as much as and hour.  I've figure 
out it's SA because the SA check as taking 8-12 seconds, which was about 
75%+ of the processing. I've been trying to sort through my rulesets to 
see which one might be causing the problem with no luck.  I went ahead 
and removed all the custom rulesets and now it's soo much worse.  Now 
the SA check is taking 45 seconds (99%)!  please help.  Why would it 
take longer with fewer rulesets?  The machine load is back down, but I 
think this will slow mail down further.  I'm at a loss.  What else can I 
do to optimize the performace?


Thanks
--
Anne