March 15, 2019 — Testimony

Pursuant to the Public Notice issued by the Consumer and Governmental Affairs Bureau,
the National Consumer Law Center (NCLC) files these comments on behalf of its low-income
clients and Consumer Reports, Consumer Action, Consumer Federation of America,
Electronic Privacy Information Center, the National Association of Consumer Advocates,
and Public Knowledge. NorthStar Alarm Services, LLC. (NorthStar) requests in its petition that
calls made with soundboard technology, which uses audio snippets of a prerecorded voice in calls to
consumers, should not be governed by the explicit requirements and limitations imposed on calls
with a prerecorded voice under the Telephone Consumer Protection Act (TCPA).