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FAQ says it’s not spam unless it is bulk and unsolicited.  If I take that literally, the message sent only to my domain name registration address (pretending that I must immediately “register” my domain with them else my (nonexistent) customers won’t be able to find me) isn’t spam because it is not bulk.  Bad wording, or bad interpretation?

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There is a small catch on that FAQ page where emails can be personalized, but still unsolicited.

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However, email containing the recipient's name is not always legitimate. For example, if someone writes a personalized message, but fails to address any subject which is specific or relevant to the recipient ("Kelly, get the lowest prices on prescription drugs!" is an example), it is safe to assume the message is spam.

I would still say that they send one to you about your domain and send one to me about my domain, it would fit the definition of opt-out and would be something that the sender is doing in bulk, just trying to use the domain to "kinda personalize" the message.

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