What does "Initiate" Mean, according to the CAN-SPAM Act?
1. The party who originates or transmits messages, or “procures” the origination or transmission of commercial email.
2. In other words, CAN-SPAM applies to the “sender.” Who’s the sender? The guy who pushes the “send” button at 2am? The entire deployment team? Answer: the entire company in charge of sending the email.
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