Comment Number: OL-101603
Received: 11/27/2004 7:00:00 PM
Organization:
Commenter: Frank Barton
State: ME
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 urge you not to modify the rules at all to permit recorded messages, as these are even more annoying than human messages. for most if not all pre-recorded messages, there is a substantial period of "Dead Air" before the message kicks in. Also often times, if you hang up while one of these messages is playing, the line is not release for you to make another call for some time (The longest I ahve personally experianced was over a minute) If anything, I would ask you to enact a measure such that *all* pre-recorded messages would be banned, not only from the "Do-Not-Call" list numbers, but from all forms of telemarketing. Also making pre-recorded political messages illegal. Additionally I have found that the limits of "Pre-existing business relationship" are often streched, in order to allow more unsolicited calls. I urge the FTC to make rules as to pre-exisiting bussiness relationships much more stringent and explicit. As to the replacement of "measured per day per calling campaign" with "measured over a 30-day period." My personal Response would be a flat out "NO" If such an ammendment must be passed, I would suppliment the rule to the effect of "Measured per day per calling campaign, with a 30 day average not to exceed..." though this I feel opens the rule up for more "Tweaking" which 30 days is chosen for the average. I urge the FTC to keep the rule as written, once again making the rule more specific and explicit, as in "Measured per day per calling campaign, from Midnight to Midnight, Eastern Time" Or something to that effect. In Summary, I urge the FTC to reject the suggestions as listed above, and to make the TSR more explicit as to what is permitted in order to prevent abuse of the system. Thank you for your time