I want to add that what we've also heard is that the act provides for statutory damages. In terms of the actions that would be brought forward by individuals, there's compensation for actual harm done, but there's also prescribed statutory damages that can be awarded. That is based on.... Non-compliance, in and of itself, would be a factor in granting individuals compensation for that. What we heard from stakeholders is that was a particular concern in the context of the private right of action, specifically, where you didn't necessarily have to demonstrate harm, that statutory damages could be awarded simply for having received a commercial electronic message that you didn't consent to. For this you could be awarded compensation. That's what elevated that risk.
On September 26th, 2017. See this statement in context.