V. 

OTHER RECOMMENDATIONS. 

Cox respectfully requests that the Commission consider the following additional 

recommendations regarding its proposal to amend the TSR. 

A. 

Caller ID Blocking. 

Cox generally supports the FTC's proposal to prohibit the falsification of caller ID 

information or to block the transmission of caller ID information when a telemarketer is 

employing equipment capable of transmitting the name of the calling party and/or a telephone 

number at which consumers can reach the calling party.  However, Cox, like many telemarketers, 

often uses large  trunk side  connections (also known as T1 lines) because they are a cost 

effective means of making many calls.  Often these connections are incapable of transmitting 

caller identification information, or are capable only of transmitting the telephone number for the 

trunk exchange.  In these latter situations, telemarketers should be allowed to suppress the 

transmission of the phone number associated with the trunk exchange because these numbers 

cannot be used by consumers to contact the telemarketer.  The receipt of such numbers as caller 

identification information serves no useful purpose and tends only to confuse consumers.   

Accordingly, Cox requests that the Commission clarify that the use of equipment and 

telecommunications services that are incapable of transmitting the name of the calling party 

and/or a telephone number at which the calling party can be reached will not in and of itself, 

constitute  blocking, circumventing, or altering the transmission of, or directing another to block, 

circumvent or alter the transmission of  caller identification information within the meaning of 

the TSR.

104

  Similarly, Cox requests that the Commission clarify that the failure to transmit a 

104

 Proposed Rule   310.4(a)(6). 

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