The myth of the low complaint rate

I have been reading the complaints filed by Holomaxx and will have some analysis and information about them probably Monday or Tuesday next week. I’ve been keeping an eye on the press and something that Ken Magill said caught my eye.

Specifically, HolomaXx alleges, its Microsoft complaint rates have been consistently at or below 0.5 percent and its Yahoo complaint rates have been at or below 0.1 percent.
Spam-complaint rates are a significant metric ISPs use to determine if incoming email is wanted by recipients or not.

This is not exactly true. Sender who have mail blocked at the edge or filtered into the bulk folder have extremely low complaint rates.
I’ll say it again, because it is critically important to understand.
Bad senders who do not get email to the inbox have very low complaint rates.
Why? ISPs measure complaints as a percentage of the emails that make it to the inbox. If mail is not hitting the inbox then the complaint rates are zero.
I understand this is a bit of a catch 22, in that to get a good reputation you need to get mail to the inbox and to get mail to the inbox you need a good reputation. But I hear a lot of spammers tell me they absolutely can’t be sending spam because their complaint rates are so low and it’s just not true.