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Strange Decision Watch: One Complaint? Really?

By Ken Magill
Esteemed online security reporter Brian Krebs recently posted an article on his site detailing how a hosting-company entrepreneur turned his business around by kicking a bunch of spammers off his network.
The article contained one eyebrow raiser of a passage about which I’d like some delivery experts to weigh in.
First some background:
“A serial entrepreneur as a young teenager, Peter Holden founded several online companies by the time he turned 20 and started Tulsa, Okla.-based hosting firm HostWinds,” Krebs wrote. “The company grew modestly but steadily — relying on more than two dozen servers and bringing in revenues of about $15,000 per month.
“That is, until Holden got his first email marketing client who offered to double HostWind’s monthly income in one day.
“’I remember driving down from Tulsa to Oklahoma City to visit this client,’ said Holden, now 25,” according to Krebs. “’It was July 2012, and it was super hot in the car because I didn’t have air conditioning. But I remember thinking it was really cool to have a client who was local and interested in using our services.’”
In the ensuing two years, HostWinds acquired a bunch of clients whose money was green and who were reportedly CAN-SPAM compliant, according to Holden.
But they were reportedly some pretty sloppy mailers. HostWind reportedly earned a Spamhaus listing and was reportedly blocked wholesale from reaching AOL addresses. So Holden took the admirable step of kicking the sloppy mailers off his network.
But then comes the eyebrow raiser:
“’I was in Dallas to visit our data center, and was in my hotel room doing planning in a notebook, and decided this was unsustainable,’ he [Holden] recalled. ‘The only [mailers] who were left were those with zero abuse complaints, and most of these were just doing regular newsletters. We gave up or lost about $150,000 in monthly revenue from that decision, a huge portion of our business.’
“As painful as it was monetarily, the company reinvented itself over 2014 and 2015, and is now more profitable and sustainable than ever, Holden said. HostWinds now terminates mailers after a single abuse complaint, and Holden said he can now spot an email marketer from a mile away.”
Can’t we all spot an email marketer a mile away? The commercial nature of the messages would be a hint. 
According to Krebs, Holden said most of the clients he terminated were shady, negative-option marketers who would get people to fork over their credit card information for automatic monthly charges and make it difficult for customers to opt out. Maybe when he says “marketer” he means “negative-option marketer,” not, say, Nordstrom or L.L. Bean.
But not all negative-option marketers are bad. Think: Book-of-the-Month Club or Dollar Shave Club, to name two.
And termination after a single abuse complaint? This is where I‘d like some deliverability folks to weigh in. Is it possible to run even a fully confirmed opt-in commercial email program without ever getting a single spam complaint?
I have personally received spam complaints over my Thursday promotional emails—granted, not many—even though my list is double opt-in and I explain in the confirmation message exactly what subscribers can expect.
This is not a shot at Krebs or Holden. It simply seems highly unlikely to me that it’s possible to run a complaint-free email marketing program.
Is it possible? Anyone?

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Terms: Feel free to be as big a jerk as you want, but don't attack anyone other than me personally. And don't criticize people or companies other than me anonymously. Got something crappy to say? Say it under your real name. Anonymous potshots and personal attacks aimed at me, however, are fine.

Posted by: Karen Balle
Date: 2015-08-12 17:57:55
Subject: As with everything in deliverability, it depends.

A single, well-formed, trusted complaint is enough to launch an investigation, as Mickey points out. If that investigation leads to evidence that the customer is not in compliance with the AUP and said customer refuses to bring themselves into compliance, then yes, a single complaint can be sufficient grounds for termination. A single complaint, in and of itself, no matter how well-formed should not lead to immediate termination. It's less about the complaint and more about what investigating the complaint uncovers coupled with the customer's willingness to adjust their practices that determines whether or not the customer is terminated.
Posted by: Catherine Jefferson
Date: 2015-08-11 16:05:03
Subject: Bulk Email with no complaints

Nuking an account on a single complaint is guaranteed to hurt honest people as well as spammers. I'm not a fan of it, and (as Ken knows and many of you know) I've been involved in anti-spam activism for a couple of decades now. Even somebody who is doing *everything* right will occasionally make a mistake. However, many ESPs and ISPs (especially those that focus on small senders or small businesses) don't have the resources to hire a professional abuse or compliance person. They also can't afford customers that ruin their reputations and get their IPs on blocklists or blocked at major companies. It's a tough spot to be in.
Posted by: Richard
Date: 2015-08-11 15:24:17
Subject: Complaint type

I think he means provider-to-provider abuse complaints. This is where a network operator lodges a complaint based on some large pattern of spam. These types are very rare for legitimate senders. Source: hosting industry jargon.
Posted by: Mickey Chandler
Date: 2015-08-11 15:19:29
Subject: Sure, but it depends.

I've had clients disconnected after a single complaint, and I've had other clients who weren't disconnected after dozens of complaints. This is one of those "it depends" scenarios. We have rules which govern a client's use of our system. We can (and have..and will again I'm sure) launch an investigation into the practices of a client on the strength of a single, well-formed complaint. When that investigation turns up evidence of a client who isn't playing by the rules that the rest of our clients must live by, we'll take appropriate action to see that they come into compliance or leave. But the complaint needs to be a good one if I were to use it to launch an investigation leading to a breach notification and eventual termination. Someone writing in to say "Ken Magill is an alcohol-soaked, gin-swilling jerk" wouldn't do it. It'd just be evidence that someone didn't like you, which isn't a breach-able offense.