From: John Mabie Sent: Tuesday, June 5, 2018 4:41 PM To: Kristi Thornton; Christina Clearwater; Karen Schroeder Subject: FCC Public Comment Requerst Kristi, Christina and Karen, I've never submitted anything to the FCC or any Federal agency for that matter, so please forgive me . . . I could not figure out how to properly submit my comments so I'm just sending you and email . . . PUBLIC NOTICE DA 18-493 Released: May 14, 2018 CONSUMER AND GOVERNMENTAL AFFAIRS BUREAU SEEKS COMMENT ON INTERPRETATION OF THE TELEPHONE CONSUMER PROTECTION ACT IN LIGHT OF THE D.C. CIRCUIT’S ACA INTERNATIONAL DECISION CG Docket No. 18-152 CG Docket No. 02-278 Comment Date: June 13, 2018 Reply Comment Date: June 28, 2018 In my opinion the only outbound call center technology that should be regulated or prohibited is "random or sequential dialing." Of these two, only sequential is really bad. As we know if a dialer is programmed to call numbers sequentially eventually a string of sequential phone numbers will be called that causes a great deal of inconvenience . . . For example, if a hospital or large company owns a large block of sequential phone numbers and a dialer calls all those numbers one after another the continual calling would flood an entire department (or floor of a building). This is clearly a nuisance and a great inconvenience, and should NOT BE ALLOWED. While the prohibition of sequential dialing makes perfect sense to me, the TCPA's problem with ATDS's makes no sense to me. An ATDS is just an efficient way to dial a list of phone numbers, it simply automates the act of a person manually dialing phone numbers. There is nothing inherently wrong with dialing "efficiency." A person receiving (answering) a phone call simply hears the phone ring and answers it . . . HOW THAT CALL WAS PLACED MAKES NO DIFFERENCE. Any and all rules/laws that vilify the use of an ATDS are ill-founded. The inclusion of ATDS restrictions in the TCPA law seems like political grandstanding. By including ATDS language in the TCPA regulations it appears lawmakers are protecting consumers, but the ATDS law provides no consumer protection; it merely forces call centers to be less efficient. There are no good reasons for the FCC to restrict or prohibit the use of an ATDS. Perhaps I am missing something (?). In the FCC's view, what consumer harm is caused by an ATDS? -John Mabie -- John Mabie President California Marketing Group 858-279-5585 X101 www.calmarketing.com