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Comment by andrewla

It's hard to see the steelman case for this. The transcript of their objections at the initial hearing are on page 13 of the transcript [1]

> The FTC's highly prescriptive proposal requiring numerous disclosures, multiple consents and specific cancellation mechanisms is a particularly poor fit for our industry. Our members offer services in a variety of custom bundles. They're provided over a wide range of devices and platforms. Consumers, for example, frequently subscribe to a triple play bundle that includes cable, broadband and voice services. They may face difficulty and unintended consequences if they want to cancel only one service in the package.

> The proposed simple click-to-cancel mechanism may not be so simple when such practices are involved. A consumer may easily misunderstand the consequences of canceling and it may be imperative that they learn about better options. For example, canceling part of a discounted bundle may increase the price for remaining services. When canceling phone service, a consumer needs to understand they will lose 9-1-1 or lifeline services as well. Especially important, low-income consumers could be deprived of lower-cost plans and special government programs that would allow their families to keep broadband service.

I mean, except for the 9-1-1 point, I guess I feel like all of those policies -- the bundling in particular -- should ALSO be disallowed.

[1] https://www.ftc.gov/system/files/ftc_gov/pdf/ftc-negative-op...

parent andrewla 2 years ago

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