threatens to disrupt the continuity of legitimate business relationships and deny consumers access 

to valuable communications from businesses that they know and trust.  

For example, Cox newspapers routinely contact their subscribers to remind them when 

subscriptions are due for renewal to avoid a disruption in delivery.  Similarly, the newspapers 

contact their subscribers when they fa ll behind in their payments to inquire as to whether those 

customers still wish to receive a paper and determine if a more flexible billing option or a 

different delivery schedule or frequency would better suit the customers' needs.  Sales and 

customer service discussions are commingled in these retention calls, which plainly benefit 

consumers and are vital to Cox newspapers' ability to operate in an industry with an annual 

churn rate of almost 60 percent.   

Similarly, Cox cable television systems use telemarketing campaigns to contact their 

customers when new services have become available in their neighborhoods and to apprise them 

of free programming previews or special promotional offers and discounts.  These call generally 

are welcomed by Cox's customers and very rarely result in do  not call requests.  For example, 

Cox's cable television system in Omaha, Nebraska, contacts an average of 2,000 customer 

households each month through outbound telemarketing calls.  On average, fewer than five of 

these custome rs ask to be placed on Cox's do not call list   just one quarter of one percent of all 

customers called.   Cox's Hampton Roads system contacts approximately 75,000 customer 

households on a monthly basis.  On average, these contacts elicit only between 75 to 100 do  not 

call requests, scarcely more than one tenth of one percent of the households called. 

These statistics suggest that even those Cox customers who might otherwise wish to 

prevent telemarketing  cold calls  to their homes are, nevertheless, receptive to occasional calls 

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