Joint Comments to FCC on Petition for Rulemaking and Declaratory Ruling by Cunningham and Moskowitz
Friday, March 10, 2017 – 5:00pm
VIA ELECTRONIC FILING
TO: Ms. Marlene H. Dortch
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554
RE: In the Matter of Petition for Rulemaking and Declaratory Ruling filed by Craig Cunningham and Craig Moskowitz, CG Docket No. 02-278, CG Docket No. 05-338
Dear Ms. Dortch:
The U.S. Chamber of Commerce in conjunction with the U.S. Chamber Institute for Legal Reform (collectively referred to as “Chamber”) respectfully submit these comments to the Federal Communications Commission (“Commission”) in response to its Public Notice requesting comment on the Petition for Rulemaking and Declaratory Ruling filed by Craig Cunningham and Craig Moskowitz (the “Cunningham-Moskowitz Petition”) on January 22, 2017, in the above-referenced dockets.
The Chamber strongly urges the Commission to deny the Cunningham-Moskowitz Petition, which asks the Commission to take on a rulemaking proceeding to eliminate longstanding guidelines for prior express consent upon which legitimate businesses have long relied in placing informational and transactional communications to customer-provided numbers. The actions sought by the Petition are not in the public interest, and granting the Petition to undertake a rulemaking on “prior consent” would not be appropriate or useful at this time, as further detailed below. Indeed, their approach would contravene the statutory regime, and take the FCC down the wrong legal and policy path. The Chamber urges the FCC to swiftly deny the petition…
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