Consumers Union, Consumer Action, Consumer Federation of America, National Association of Consumer Advocates, National Consumer Law Center on behalf of its low-income clients, Public Citizen, and Public Knowledge submit these reply comments on the above-referenced proceeding concerning Advanced Methods to Target and Eliminate Unlawful Robocalls. Ending unwanted robocalls remains a key concern for the undersigned groups and the consumers we represent. These reply comments briefly develop several of the points made in our original comments.

We reiterate our original points, including that the FCC should clarify that the voice providers may block clearly-spoofed calls at the request of the subscriber to the spoofed number, calls spoofed with an invalid number, calls spoofed with a number that has not been allocated to a voice provider, and calls spoofed with a number that has yet to be assigned to a consumer.

In response to other comments submitted, we reiterate our view:

  • Call recipients, except in the case of Do Not Originate, should be provided with sufficient information and be able to decide whether they want the call-blocking services described in the NPRM;
  • Any universal “whitelisting” of calls should be limited to emergency numbers, and any “challenge mechanism” should be appropriately limited; and
  • The FCC’s definition of an “illegal robocall” for the purposes of this proceeding should encompass all illegal robocalls, and be able to accommodate technologies such as ringless voicemail and robotexts.