ÿþ<!DOCTYPE HTML PUBLIC '-//W3C//DTD HTML 4.0 Transitional//EN'> <html><head><title>527292-00003.htm</title> <meta name='vs_defaultClientScript' content='JavaScript'> <meta http-equiv="Content-Type" content="text/html; charset=utf-8"> <meta name='vs_targetSchema' content='http://schemas.microsoft.com/intellisense/ie3-2nav3-0'> <meta name='Originator' content='CommentWorks'></head><body><Table> <tr><td><b>Comment Number: </b></td><td>527292-00003</td></tr> <tr><td><b>Received: </b></td><td>2/10/2007 1:20:45 PM</td></tr> <tr><td><b>Organization: </b></td><td>Brokerblogger.com</td></tr> <tr><td><b>Commenter: </b></td><td>Bill Kelm</td></tr> <tr><td><b>State: </b></td><td>TX</td></tr> <tr><td><b>Agency: </b></td><td>Federal Trade Commission</td></tr> <tr><td><b>Rule: </b></td><td>FTC Workshop Analyzing Negative Option Marketing</td></tr> <tr><td>No Attachments</td></tr></Table> <hr><P><b>Comments:</b></p>I have studied this &quot;Auto-Renewal&quot; issue fairly well as a consumer advocate, and I've come to the conclusion that unless many &quot;return receipt&quot; e- mail reminder notices are sent out well in advance of renewal dates, auto-renewal has more negatives than positives for the consumer, and maybe even sellers if they have easily cancelable subscriptions without any &quot;pro ration&quot;. Even if a reputable company like Consumer Reports sends more than their once a year subscription reminder e-mail, if the subscriber is on a long vacation, has his Internet service down for some reason ( my FiOS lifeline for Internet, phone, and TV was recent cut somehow, and they were all &quot;out of service&quot;), or is just ignoring his e-mails due to &quot;divorce depression&quot;, etc., then he may be billed automatically for something he no longer wants. Then, even if it is easy to cancel a month later without pro ration when the buyer gets his PayPal or credit card bill, then he has to monitor future bills to make sure the seller follows through in a timely way with the adjustment credit. He also loses the use of those pending credited funds until the adjustment comes through. I blogged about this in &quot;&quot;Auto-Renewal&quot; Complaints May Lead To FTC Rules&quot; ( http://www.brokerblogger.com/brokerblogger/2007/01/autorenewal_com.html ) = I AM NOT TRYING TO PROMOTE MY BLOG, BUT ONLY TRYING TO HELP AVOID THE GROWING NUMBER OF COMPLAINTS (I have a &quot;Google Alert&quot; for the keywords &quot;Auto-Renewal&quot; and &quot;Automatic Renewal&quot; and see many complaints that way) I also just wrote the details of my &quot;return receipt&quot; strong suggestion in &quot;A Solution For &quot;Auto-Renewal&quot; and New FTC's Negative Option Marketing Emphasis&quot; ( http://www.brokerblogger.com/brokerblogger/2007/02/a_solution_for_.html } = I hope Lydia Parnes, FTC s director of the Bureau of Consumer Protection gets a chance to read my suggestion, as I believe it is the only way consumers can be protected! I sent a copy of this to negativeoption@ftc.gov as well as smbiz@mail.house.gov, info@nclnet.org, and ben@consumerist.com. Sincerely, Bill Kelm </body></html>