Does cold outreach count as “marketing”?
Usually Yes. Cold outreach to potential customers is commercial electronic messaging under most regulations. CAN-SPAM, GDPR, and CASL all apply to cold prospecting emails.
The commercial nature comes from the ultimate goal (business relationship, sales) not the immediate content. "Just introducing myself" is still commercial if business intent underlies it.
Cold outreach faces the same regulatory requirements as explicit marketing. Consent, unsubscribe, identification, and other requirements apply.
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