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WC 07-135, CG 02-278 et al: USTelecom Comments on Do Not Call Violations


The letter from the National Association of Attorneys General raises issues regarding the legal, practical and technological challenges that may arise regarding the implementation of certain call-blocking technologies by common carriers to address the problem of robocalls. USTelecom welcomes this discussion since we share many of the same concerns raised by NAAG and others regarding abuses of the Do-Not-Call framework. USTelecom continues to work cooperatively with a broad range of stakeholders on this issue in order to find a practical, workable solution to the problem of telephony abuse and fraud resulting from unwanted, and sometimes unlawful, robocalls. USTelecom understands and shares the widespread frustration resulting from violations of the Do-Not-Call framework. Such calls are not only an annoyance, but criminal elements can at times exact financial and emotional harms upon unsuspecting or vulnerable consumers. Given the realities of today’s competitive marketplace, carriers must develop and deploy effective tools that might operate to mitigate annoying – and at times, criminal – robocalls in order to retain their customers and stave off potential competitive alternatives. But in addition to the harm many robocalls cause consumers, these unwanted calls impact USTelecom’s own member companies. In addition to dedicating significant customer service and fraud response resources towards this issue, these calls can also adversely impact our companies’ networks. In extreme instances can degrade and disrupt services in a provider’s impacted area.