Sorry, but both the case law and the legislative intent are pretty clear on that. Even free services fall under this rule if the type of service is generally provided for a fee, even if the specific service is free. The section is a fairly direct implementation of article 5 of EU Directive 2000/31/EC.

EU directive is much clearer on the subject.

(c) the details of the service provider, including his electronic mail address, which allow him to be contacted rapidly and communicated with in a direct and effective manner;

Replying with an automated answer saying that actual human response is not an option, is certainly not direct and effective.

> commercially, GENERALLY in return for a fee

(generally is emphasized by me)

The argument can be made that showing someone ads in return for services is offering things commercially. C.f. free tv channels with ad-breaks.