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Email Marketing: Is it CAN-SPAM appropriate to send emails to customers who have not explicitly given permission?
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The Creator's Lawyer ™ - Ticora Davis, Trademark and Copyright Attorney answered:

You do not have to request permission to e-mail customers; however, you must provide them with an option to opt-out of receiving your electronic communications, in addition to the other requirements to remain in compliance with the CAN-SPAM Act. Here's an excellent resource for your reference: https://www.ftc.gov/tips-advice/business-center/guidance/can-spam-act-compliance-guide-business

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