No. It's more or less someone who has come to a Microsoft event five years ago—or let's say three years ago—and for whom we have a piece of documentation saying they were there. Perhaps it's a survey, but at that time it didn't have an explicit statement saying that they expected to receive email from us. That interpretation is causing challenges for us right now as we look to implement the full language of the act.
On October 24th, 2011. See this statement in context.