The U.S. Chamber of Commerce (“Chamber”) respectfully submits these ex parte comments to the Federal Communications Commission (“Commission” or “FCC”) in response to the above-titled Notice of Inquiry (“Notice”).1 The Chamber appreciates the Commission’s issuance of a Notice to understand the implications of emerging technologies, such as artificial intelligence (“AI”) on robocalls and robotexts and the Telephone Consumer Protection Act (“TCPA”).
The Chamber believes it is critical for the responsible and ethical use of AI to unlock innovation and improve the lives of Americans. We are actively engaging with more than a dozen federal agencies’ efforts on AI as well as their international, state, and local counterparts. Last year, the Chamber’s Artificial Intelligence Commission on Competitiveness, Inclusion, and Innovation (“Chamber AI Commission”) released a comprehensive report on AI, which among other policies called for a risk-based regulatory framework.2
At this point, new regulations or legislation to address AI-enabled robocalls or robotexts would be premature. Instead, the Commission should leverage existing law, collaborate with industry and other governmental entities as well as other stakeholders to further its understanding on AI, and utilize its current enforcement tools to combat bad actors. For this reason, we appreciate the Commission’s February Declaratory Order clarifying that AIgenerated voices amount to an artificial or prerecorded voice under the TCPA.
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