The act does define the word initiate, but it defines it to mean what the person who originally sends a message does so they can exempt relays. It's not originating or transmitting a message if you break off the connection before a message is fully transmitted.

> The term "initiate", when used with respect to a commercial electronic mail message, means to originate or transmit such message or to procure the origination or transmission of such message, but shall not include actionsthat constitute routine conveyance of such message.

I also don't think (but with less certainty) that what isn't fully sent counts as a message, as the primary purpose is verifying if the address exists. Message is defined as

> any electronic mail message the primary purpose of which is the commercial advertisement or pro-motion of a commercial product or service