RILA Comments on Petition for Rulemaking and Declaratory

The Retail Industry Leaders Association (“RILA”) respectfully submits these Comments in opposition to the Petition for Rulemaking and Declaratory Ruling (the “Petition”) filed by Craig Moskowitz and Craig Cunningham (“Petitioners”). RILA is the trade association of retailers, product manufacturers, and service suppliers that routinely engage in consumer outreach directly implicated by the Petition. The Petition’s proposed changes to the consent regime reflected in the Commission’s Telephone Consumer Protection Act (“TCPA”) rules are of deep concern to RILA and its members.