These Reply Comments, filed by the National Consumer Law Center on behalf of its low-income clients, supplement the Comments filed on February 10, 2023, in this docket. Sections IV(A) and (B) of our primary comments explain our position that DentalPlans.com (DentalPlans) has not shown that consumers provided prior express written consent as required for prerecorded calls containing telemarketing. These Reply Comments elaborate on one point made in our primary comments: that DentalPlans has not shown and cannot show that its processes for obtaining prior express written consent—either through an exchange over the internet or verbal conversations between its representatives and consumers—met the FCC’s requirements for prior express written consent to receive prerecorded telemarketing robocalls.
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