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Bumped into a copy of can-span rules, the 2 messages referred to in my post above were not in compliance even though techically the words were there:
1. The exact phrase "SEXUALLY-EXPLICIT:" must be contained in capital letters as the first 19 characters at the beginning of the subject line. This phrase in the subject line must be in ASCII format.
2. The exact phrase "SEXUALLY-EXPLICIT:" must be in capital letters as the first 19 characters in the "brown paper wrapper" area of the email message. The Brown Paper Wrapper refers to the opening portion of the e-mail that is immediately visible to the recipient, without scrolling down or taking any other affirmative steps to view the message. Sexually explicit material can be displayed beneath the "brown paper wrapper" area of the email message or accessible by clicking on a link.
3. A valid postal address must be displayed in the "brown paper wrapper" area of the email message.
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