|Received:||11/27/2004 7:01:37 PM|
|Subject:||Trade Regulation Rule on Telemarketing Sales|
|Title:||Notice of Proposed Rulemaking, Request for Comment|
|CFR Citation:||16 CFR Part 310|
Comments:First, I want to thank the FTC for creating the Do-Not-Call system. It has reduced the intensity of phone-based intrusions in our household. For that we are grateful. Second, I wish to recommend against the proposed amendment. Permitting pre-recorded messages is a bad idea that will only boost the volume of phone spam dumped on consumers. Pre-recorded messages reduce the cost of mass-marketing. Reducing the cost of a direct marketing calls will boost the volume of such calls by lowering the threshold of business value for such calls. I would suggest you study this issue, but I suspect that the cost reduction will be one or two orders of magnitude (from costing dollars/call to costing pennies/call). I would suggest you consider the elasticity effects of this and the potential that an order of magnitude reduction in the cost of a call will create an order of magnitude increase in call volume. If the call is not worth the labor of a real person to make the call, it is not worth the labor of the consumer who must answer that call. Thank you.