On Sun, Jul 10, 2022 at 3:56 AM Jarland Donnell via mailop <mailop@mailop.org> wrote: > > Is it normal to request such an opinion?
What if it isn't normal? Google has asked the FEC for an opinion, and the FEC has launched a consultation. If it is not normal, it is extraordinary in a positive sense and signals a remarkable path forward towards positive changes in the way policy is proposed and processes are developed. Google's proposal looks good. Perhaps good to go as proposed, and could work well in America, with some hitches and unforeseens as expected of any new process. If Google wishes to be a little more thorough, without taking a lot of time to do that, here are some observations based on a quick look at the subheadings of the documents, from an average user with inadequate technical expertise: 1. Spam filters run on algorithms that are far from perfect and it is not easy to set right false positives in a time sensitive manner, especially in this context, wherein a candidate finds his email messages falsely filtered out. 2. Spam filters not only block messages based on email content and pattern, but also based on IP reputation, which is even more difficult to troubleshoot, and takes longer to fix. 3. Political campaign messages are by nature "bulk" in the sense that a candidate mails thousands, if not hundreds of thousands in his constituency/region or country. These filters, from the way they work, do not treat bulk messages kindly. 4. Does the proposal contain safeguards to compartmentalize campaign messages - for instance, is there some way Google can ask for some form of assurance that a candidate for the Senate is sending messages only to the voters in his State? 5. Most candidates would not sufficiently understand the technical nuances of how email works -not to be taken as a disparaging comment, there are too many technical nuances and it is not fair to expect those in the realm of policy-making to have spent years mastering the complexities and nuances of this technology that is new everyday. The document from Allen & Overy includes a section on "Tools to aid bulk mail senders" with a helpful footnote that points to Postmaster tools https://gmail.com/postmaster/ which requires DKIM and SPF to be implemented, which requires signs and tokens that might seem ordinary for those in the DNS, but might at least seem complex for the rest of humanity. Google may have to make it easy by making the qualifying process as simple as that of (alternatively) requiring the candidate to use an approved/accredited mail server professional / Security professional / accredited and trusted bulk mail manager, however controversial it might be for Google to choose companies / individuals for such certification. 6. A pilot is a pilot. For a pilot program, the proposal as drafted appears safe enough. As the pilot transitions into a full program, the FEC may have to work with organizations such as Google and with the Internet Community on making this program relevant and geographically pertinent across the Internet, taking into consideration several other campaign related factors that are not foreseen in the purview of this pilot that appears focused at the moment on US elections. 7. The proposal futhers freedom of expression and enables free flow of information. At the same time, Google may please look for unforeseen expansions of proposed procedures such as identify verification and eligibility requirements. Thank you. >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) > > > > > > > > _______________________________________________ > > mailop mailing list > > mailop@mailop.org > > https://list.mailop.org/listinfo/mailop > _______________________________________________ > mailop mailing list > mailop@mailop.org > https://list.mailop.org/listinfo/mailop _______________________________________________ mailop mailing list mailop@mailop.org https://list.mailop.org/listinfo/mailop
