CAN spam act question

[Undead Hunter]

Hi Folks:
A quick question about the new anti-spam act - I have a client that has gathered the emails of contacts in 30 major companies - can they email them directly *once*, with an opt-out (or opt-in for more) preference if the companies want more?

Assuming everything else is above board, and it is - or does that end up as legal under the new act?

Ethically, I'd prefer to see them have permission first, but I can't put a gun to their heads and make them do this. I've given all the dire warnings I can...

Any info is appreciated.

[yowza]

I believe that it is allowed as long as you follow the rest the guidelines: listed address, easy opt-out option, etc.

However, I'm no lawyer, so don't listen to me.