In reply to dlouwe.

It depends if you're then using the commenter email for marketing (which, let's face it, many blog posts fall into).

I work for an org with 18,000 employees, and we've had to have numerous discussions over the last 18 months re. CASL, and what constitutes CEM.

Blog comments (based on the option of further marketing from them) is part of the ongoing discussion.

Fun times! ;-)