I don't have concerns about the level of consent that's required under ECPA.
Just to give you a bit of background, PIPEDA is a law of broad applications. It was created to work in a variety of situations. My view, our view, is that PIPEDA is a floor, not a ceiling, and that the form of consent in PIPEDA should be applied by looking at the sensitivity of the personal information. Express consent or opt-in consent is a higher form of consent; it's more privacy-sensitive than implied consent. I think that's appropriate here, because it's going to be effective in dealing with the problem that is spam.