I never got a response when I wrote to the FTC, requesting formal guidance as to whether having to disable NoScript (a browser security measure) to complete a CAPTCHA to unsubscribe from email spam satisfies 16 CFR § 316:
"Neither a sender nor any person acting on behalf of a sender may require that any recipient pay any fee, provide any information other than the recipient's electronic mail address and opt-out preferences, or take any other steps except sending a reply electronic mail message or visiting a single Internet Web page"
"Neither a sender nor any person acting on behalf of a sender may require that any recipient pay any fee, provide any information other than the recipient's electronic mail address and opt-out preferences, or take any other steps except sending a reply electronic mail message or visiting a single Internet Web page"
https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C...
A simple reading says, no. But I guess they don't want to put that in writing.