|Received:||11/2/2006 8:50:58 AM|
|Subject:||Telemarketing Sales Rule|
|Title:||Request for Public Comment|
|CFR Citation:||16 CFR Part 310|
Comments:I designed and built a software system that is used to send alerts and notifications. One of its modes is via telephone. Folks are using the system to remind little leaguers of their game schedules, other are using it to remind seniors to take their medicine and some may be using it to upsell their products. Our system relies on the current standard of "pre-existing relationship" to prevent spammers. Our system allows opt-out to prevent unwanted messages. We even tell our customers that if we find out that they are spamming, it voids their contract and we will turn off their service. My system supports interactive voice as well as pre-recorded voice messages. It supports both because some users just are not comfortable with building interactive messages and just want to use a recorder. I believe your proposal is over broad and will impact the system I built and the folks using it. Requiring written consent is big burden and does not reflect today's business environment where so much activity is conducted via the web. Web based automated systems have been a big boon for seniors. Systems such as mine that can provide prescription reminders are also a great benefit to seniors. I realize you are trying to prevent voice spammers. But please realize that you may be having a negative effect on many other systems, and people who are provided with wanted services but who just happen to use similar technology.