This is a definition of spam, not the only definition of spam. In Canada, which is relevant here, the legal definition of spam requires no bulk. Any company s

This is a definition of spam, not the only definition of spam. In Canada, which is relevant here, the legal definition of spam requires no bulk. Any company sending an unsolicited email to a person (where permission doesn't exist) is spamming that person. Though it expands the definition further than this as well.