>The effect would be to route ALL mail from the TLD to the FTC, but
>some of that mail might be non-spam

Not to be side tracked into an argument, but I'm sure
we all know of some domain names that are never used
for any purpose but spam.
It's fairly safe to assume that there won't be anything
but spam coming from domains such as:
  emailbargain.com
  optmailer.net
  admanmail.com

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