| Comment Number: | OL-100581 |
| Received: | 11/27/2004 11:46:45 AM |
| Organization: | |
| Commenter: | Michael Kuras |
| State: | MA |
| Subject: | Trade Regulation Rule on Telemarketing Sales |
| Title: | Notice of Proposed Rulemaking, Request for Comment |
| CFR Citation: | 16 CFR Part 310 |
| No Attachments |
Comments:
I oppose this dilution of the existing regulations. The existing regulations are intended primarily to secure the rights of the called party -- specifically to secure the called party from unwanted intrusions. The proposed change would dilute this protection without any countervailing advantage to the called party. Pre-recorded messages from sellers or their agents, regardless of the sellers' relationships to a potential buyer, clearly cannot qualify as a reasonable elaboration of existing regulations since pre-recorded messages by their very nature must be generic and not the expression of any specific buyer-seller interest. I am unaware of any advantage that would accrue from the proposed change except to erstwhile sellers and their agents. This of course illuminates my own assessment of the FTC and how I judge its merit as an agency entrusted with the public interest. ML Kuras