I'll just mention one criterion that is relevant to your question.
One of the criteria, which are to be assessed on a case-by-case basis under PIPEDA as to whether explicit consent is required, involves the expectation of individuals. If we apply that standard to CASL, the question becomes what the reasonable expectation of consumers is in terms of receiving unsolicited communications from organizations. Do they find them helpful, because they help them make certain decisions, or do they find them unhelpful because—