October 10, 2024 — Comments

We recommend that for calls that include AI-generated technology: before callers can make AI-generated calls that may employ interaction with the recipient, the callers must obtain explicit consent from called parties to receive calls that use this technology; and second, that these AI-generated calls must include a disclosure at the beginning of each call that the call uses this technology. Also, we believe that the FCC can provide protection for AI-generated calls used by person with a disability by providing a definition of “artificial voice” to exclude a mechanical voice that is generated by an assistive device by a person with disabilities to transmit their words over the telephone. In this situation, the vocalization of the words should not be considered an “artificial voice” for purposes of the TCPA. Finally, we strongly oppose allowing telephone service providers to deploy technology that enables network level surveillance of calls.

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