Telephone sales calls also provide CIMedia's current customers the opportunity to take 

advantage of new products and services as they become available and to receive the kind of 

individualized customer service that they have come to expect from Cox. 

DISCUSSION 

I. 

THE PROPOSED NATIONAL DO NOT CALL REGISTRY WILL 

UNREASONABLY RESTRICT COMMUNICATIONS WITH EXISTING CUSTOMERS 

AND INTERFERE WITH LEGITIMATE RELATIONSHIPS BENEFICIAL TO 

CONSUMERS. 

The FTC proposes to create a centralized national  do not call  registry to be maintained 

for a trial period of two years.

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  Pursuant to this proposal, consumers would contact the FTC and 

place their telephone number on the national registry, making it illegal for companies within the 

FTC's jurisdiction to call them for telemarketing purposes.  Once consumers have placed their 

telephone numbers on the national registry, the only way they can authorize a company to 

contact them is to transmit their  express verifiable authorization  to be called.  This proposal 

would require companies to obtain eithe r a consumer's signed written authorization or recorded 

oral consent to be called. 

Unlike virtually every state that has enacted analogous do not call registry laws,

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 the 

FTC has not proposed an  established business relationship  exemption that would permit 

telemarketers to call parties with whom they have a preexisting business relationship, regardless 

of whether those parties' numbers are on the national registry.  Accordingly, by preventing 

companies from contacting existing customers without first undertaking a cumbersome process 

of obtaining each customer's  verifiable authorization  to be called, the proposed amended Rule 

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 Proposed Rule   310.4(b)(1)(iii). 

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 Citations to the established business relationship exemptions that exist under every state  do not call  registry law 

known to Cox are compiled in a list attached hereto as Appendix  A. 

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