III. 

THE FTC'S PROPOSED RESTRICTION ON THE DISCLOSURE OF 

CUSTOMER BILLING INFORMATION IS OVERBROAD AND UNDULY 

BURDENSOME. 

The proposed amended Rule would prohibit telemarketers from receiving a customer's 

billing information from anyone other than the customer, or from disclosing or sharing any such 

information with third parties for use in telemarketing.

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  Cox's cable television systems and 

newspapers regularly use third party service bureaus or other third party telemarketing 

contractors to conduct outbound telemarketing campaigns on their behalf.  When telemarketing 

agents acquire a new customer, they necessarily transfer the customer's billing information back 

to Cox for purposes of establishing a new account, and, in the ordinary course of business, a Cox 

customer sales representative may someday refer to that account information again, including the 

customer's billing information, for purposes of processing another telemarketing transaction with 

the same customer.  Various Cox divisions also have entered into relationships with firms like 

AllConnect and ConnectUtilities that enable consumers who are planning to relocate to a new 

community to establish accounts for all of their necessary utility services and related services, 

such as newspaper and cable television subscriptions, with a single online or telephone 

transaction.  The very efficiency that these firms offer is the ability to establish, on a  one stop 

shopping  basis, multiple billing relationships with a single submission of billing informatio n.  

Cox cable systems also have entered into cross sales agency relationships with individual 

newspaper publishers and power companies in their communities designed to achieve similar 

efficiencies.  All of these relationships offer obvious benefits to consumers and most of them 

involve some exchange of customer billing information with the knowledge and consent of the 

affected customers. 

97

 Proposed Rule   310.3(a)(3). 

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