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Email List Question - Spam?

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If I'm asking this question, then it probably is spam. But I just want to double check with people who know more about the legal end of email marketing.

I'm helping someone setup an email marketing automation system. The business is getting a lot of leads from cars dot com and we were thinking about sending the leads to his list. However, after doing some thinking I realized that he might not be able to legally contact these people because they opted in through a 3rd party.

The way it works is that someone goes to cars dot com and completes a form. He can then submit a bid (if buying a car) or contact the person through cars dot com. He also gets a downloadable CSV file with all of the information about a lead (name, email, phone, etc).

Any idea if he can add these people to a list and contact them?

BTW - I'm also getting legal advice later this weekend, but in the meantime I'm also interested in seeing what people here might say.
 
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With more than 39,000 posts packed with insights, strategies, and advice, you’re not just a member—you’re stepping into MJ’s inner-circle, a place where you’ll never be left alone.

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