|Received:||11/27/2004 5:52:50 PM|
|Subject:||Trade Regulation Rule on Telemarketing Sales|
|Title:||Notice of Proposed Rulemaking, Request for Comment|
|CFR Citation:||16 CFR Part 310|
Comments:Please DO NOT change from measuring per day per calling campaign to measuring over a 30-day period. This does two things: changes from one day to 30 days, and removes the per-campaign requirement. Either will will loosen the requirements too much, and together they are a disaster. Changing from a one-day to a 30-day measurement will allow concentration on whatever days of the week that a caller desires (probably the most important days of the week). Removing the per-campaign requirement will allow some campaigns to have unlimited abandonment, as long as others make up the difference. This will unfairly favor large calling organizations, which will have the scale to create such balances. Together, these loosen the requirements so much as to make them meaningless.