|Received:||11/27/2004 7:35:10 PM|
|Subject:||Trade Regulation Rule on Telemarketing Sales|
|Title:||Notice of Proposed Rulemaking, Request for Comment|
|CFR Citation:||16 CFR Part 310|
Comments:In my opinion, a safe-harbor for automated, pre-recorded messages is a win solely for advertisers. Automated call machines are the spam of the telephone system. They represent the lowest possible cost to the caller, thus there is little incentive to strongly target the advertisement to the receiver. On the other hand, automated calls represent the maximal annoyance to the callee. The 'established business relationship' clause is far too slippery for my tastes. Advertisers will be quite liberal with this phrase. As a result, the burden is placed on the private citizen to dispute unwanted calls. I strongly oppose this change. It goes against the spirit of the do-not-call list and opens a crack in the law through which advertisers will charge.