Are CSR emails to customers "ads?"

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Question:

Does CAN-SPAM apply to those emails sent by platform employees to let their preferred customers know of new rates, etc.?

Answer:

Probably. If the primary purpose of the messages is to announce a change in terms or available upgrade to a product the customer already owns, then the message is exempt. Otherwise, if the message is sent to stimulate interest in a product the customer does not currently own, it is covered.