[singron]

I was reading CAN-SPAM and I came across the definition of "electronic mail message" in 15 USC § 7702(6)

> The term “electronic mail message” means a message sent to a unique electronic mail address.

Note that it doesn't specify anything about SMTP or any specific email protocols besides the address. I wonder if messaging systems that use email addresses as identifiers might unintentionally be subject? E.g. Ads shown through Facebook custom audiences with email address lists.

[driverdan]

I'd love to see someone bring a case asserting push notifications are electronic mail messages under CAN-SPAM.

[eli]

Seems like a stretch. A Facebook web ad isn't sent "to" an email address.