[Maddyfish]

I had this same question a while back. I found the following from a FTC Blog, where they asked candid questions from someone at the FTC. See below:

I bought a list of email addresses for people likely to be interested in my niche product. If I comply with the commercial email requirements of CAN-SPAM, do I have anything to worry about?

CHRISTOPHER: The CAN-SPAM Act doesn’t require initiators of commercial email to get recipients’ consent before sending them commercial email. In other words, there is no opt-in requirement. So in general, as long as you follow the “initiator” requirements of the Act, you can send email until the recipient asks to opt out. But buying lists like that can be risky. There is the possibility that addresses on the list belong to people who have already opted out of receiving email from your company. And there’s a risk that the list was put together using illegal means like address harvesting or dictionary attacks. Therefore, some companies choose to send marketing email only to people who have affirmatively asked to receive them or with whom the company already has a business relationship.

https://www.ftc.gov/news-events/blogs/business-blog/2015/08/candid-answers-can-spam-questions

I hope this helps.

[Maddyfish]

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