We collect 100% of our emails by opt in and document every permission. And, if you had read anything I have written you would know that I recommend that all other companies follow this policy and go beyond the legislation.

We do no mass broadcasting. A typical communication would be an email to a farmer who has told us that he has pigs, receiving a notification about a swine flu inoculation.

Really? While this might be a personal position, the evidence again Mardev available from a simple web search does NOT agree.

"Mardev is the list management division of Reed Business Information (RBI), the world's largest business information supplier. We specialize in business-to-business (B2B) lists for direct marketing campaigns. Our lists cover all market sectors including manufacturing, mining, entertainment, finance, media, building & construction & travel. We have access to over 300 B2B databases worldwide, including 300,000 Australian records."

From the Department of Trade and Industry in the UK, you even supported

changing the law in the UK asking that the law allow B2B SPAM without consent based on the opt-out principle:

http://www.silicon.com/research/specialreports/thespamreport/0,39025001,3915...

"We have reviewed the responses in detail to ensure that we provide you with an accurate list and have found that six organisations supported opt-out for business-to-business direct marketing emails."

Those six organisations, according to the DTI, were Cable & Wireless, Information & Research Services, Holiday-Rentals.com, Mardev, Masterclass and Taylor Wessing.

So, as I understand it, no only is it legal in the UK to use opt-out b2b mailing practices but your firm helped change the law for this. And your firm directly utilizes AND advertises based on this loophole:

http://www.prnewswire.co.uk/cgi/news/release?id=140795

DecisionMaker Portrait allows marketers to identify the contacts available within DecisionMaker - Mardev's business targeting database of over 2.8m named UK records - that are most likely to respond to their proposition. The model offers a sophisticated method of selecting prospects that will significantly improve response rates and win more business.

Is what you are doing legal, sure. Is it spam? In my opinion, yes.

KAM