February 10, 2023 — Comments

Pursuant to the Public Notice issued by the Consumer and Governmental Affairs Bureau, the National Consumer Law Center (NCLC) filed these comments on behalf of its low-income clients and Consumer Action, Consumer Federation of America, Electronic Privacy Information Center, National Association of Consumer Advocates, Public Knowledge, and U.S. PIRG, opposing in all respects the Petition filed by DentalPlans.com.

In its Petition, DentalPlans.com (DentalPlans) requests an “expedited declaratory ruling” that (1) “DentalPlans’ renewal notifications do not constitute telemarketing or advertising under the TCPA”; and 2) “the language in its online enrollment forms and the language used by its customer service representatives during telephone conversations with potential DentalPlans customers satisfies the disclosure requirements set forth in 47 U.S.C. § 227(b)(1)(A)(iii) . . . .” The Petition also asks that, if the Federal Communications Commission (FCC or Commission) does not provide the declaratory ruling as requested, it should “waive the application of the rules for the period prior to December 31, 2020.”