Comment Number: OL-102122
Received: 11/27/2004 8:49:53 PM
Organization:
Commenter: William Stuart
State: CT
Subject: Trade Regulation Rule on Telemarketing Sales
Title: Notice of Proposed Rulemaking, Request for Comment
CFR Citation: 16 CFR Part 310
No Attachments

Comments:

Dear Commissioners: I and many other Americans have registered to be on the telemarketing Do-Not-Call lists because we know that we do not want to be disturbed with unsolicited telemarketing calls. The elimination of these unwanted and disruptive calls was the purpose of the original legislation. I find being called by computers to be as disruptive or more disruptive than being called by human telemarketers. With computer calling, there is the additional risk of malfunction, such that callers could receive numerous unsolicited calls with no human correspondent with whom one could seek to alleviate the problem. Clearly, by allowing computerized telemarketing calls, the FTC would be circumventing the intent of the Do-Not-Call legislation, which was to allow citizens to opt-out of the nuisance of unsolicited telemarketing calls. Rather than rollback these citizen protections, I am in favor of creating an opt-in system, in which a person would need to actively register to receive telemarketing calls, rather than be forced to opt out. Undoubtably, the telemarketing industry would benefit greatly by allowing automated calls to citizens on the Do-Not-Call list. However, the interests of the nation as a whole would suffer. It has been effectively argued that the economic costs of telemarketing in lost productivity and leisure to businesses and citizens far outweigh any supposed economic benefit to the country from the telemarketing industry. To strip citizens' of their legislated protections against what is essentially "phone spam" would be appallingly bad policy. It would also invite legislative reversal. I recommend in the strongest possible terms that the proposed changes to the TSR not be adopted. Sincerely, William S. Stuart