Comment by Center for Democracy and Technology

The Center for Democracy & Technology respectfully submits the following reply comment in opposition to the petition for expedited waiver filed by Club for Growth that would allow for calling parties to make noncommercial, political calls to wireless numbers using artificial or prerecorded voice, including AI-generated voice, without prior express consent. [...] The FCC has long declared that robocalls to cellular devices are illegal per the Telephone Consumer Protection Act (TCPA), unless prior express consent has been obtained. In the aftermath of the 2024 New Hampshire robocall scam, where voters received calls in which an AI-generated deepfake impersonating Joe Biden discouraged them from voting in the New Hampshire primary, the FCC further ruled that AI-generated voices are considered artificial under the TCPA, and are therefore illegal as well without prior express consent.