Before the FEDERAL COMMUNICATION COMMISSION Washington

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 1 of 41

Before the

FEDERAL COMMUNICATION COMMISSION

Washington, DC 20544

In the Matter of )

)

Targeting and Eliminating Unlawful )

Text Messages ) CG Docket No. 21-402

)

Rules and Regulations Implementing the )

Telephone Consumer Protection Act of 1991 ) CG Docket No. 02-278

REPLY COMMENTS OF 28 STATE ATTORNEYS GENERAL

I. INTRODUCTION

The undersigned State Attorneys General (“State AGs”) submit these Reply Comments in

response to the Public Notice issued by the Consumer and Governmental Affairs Bureau,

seeking

comment on the Federal Communication Commission’s (“Commission”) proposals to, inter alia,

“ban the practice of obtaining a single consumer consent as grounds for delivering calls and text

messages from multiple marketers on subjects beyond the scope of the original consent.”

Consistent with our respective and collective offices’ efforts in combatting illegal robocalls and

text messages, and in response to those commenters advocating for measures that will provide

lesser protection for consumers, the State AGs support the Commission’s intended goal of

eliminating the current practices of the lead generation industry, unscrupulous voice service

providers, and illegal robocallers that abuse the Commission’s rules governing prior express

Further Notice of Proposed Rulemaking, Targeting and Eliminating Unlawful Text Messages, CG Docket

No. 21-402, Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, CG

Docket No. 02-278, March 16, 2023 (“March 2023 FNPRM”).

March 2023 FNPRM at 22, ¶ 58.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 2 of 41

written consent. In addition, the State AGs offer comments concerning the Commission’s

proposals with respect to text messaging.

II. PRIOR EXPRESS WRITTEN CONSENT

A. The Lead Generation Problem

Telemarketers, voice service providers, and scammers need people to call (or text). Thus,

lead generation has proliferated into a billion-dollar industry

and has become a necessary

component of the robocall ecosystem. Most obviously, there is the person or entity interested in

placing calls to potentially solicit customers for any number of products or services or to swindle

consumers into parting with their hard-earned money or personal information. Whether for

telemarketing or for scams, the entity that wants to place the calls needs to select the phone

numbers to call, needs technology to dial the calls en masse, and needs a voice service provider to

connect the calls to the recipients. Each of these necessary functions is routinely outsourced to

providers all over the globe, who facilitate and profit from facilitating robocalls.

A few months into the global COVID-19 pandemic, Assurance IQ, LLC (“Assurance”), an

insurance company, filed a petition with the Commission seeking an expedited ruling regarding

what constitutes prior express consent under the Telephone Consumer Protection Act (“TCPA”).

In its Petition, Assurance requested the Commission confirm that “where it is determined that a

calling party has sufficient information to establish a reasonable basis to believe that they have

Lead generation involves collecting personal information, including telephone numbers, from consumers

and then selling that information to third parties who want to use the leads to generate business. See also

https://www.statista.com/statistics/190328/us-online-lead-generation-spending-forecast-2010-to-2015/

(Accessed April 18, 2023).

Petition for Expedited Declaratory Ruling Regarding the Application of 47 U.S.C § 227(b)(1) of the

Telephone Consumer Protection Act, CG Docket 02-278, May 12, 2020 (“Petition”).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 3 of 41

valid consent to make the call, the caller may rely on that consent for TCPA purposes until such

time as the called party claims to the caller that he or she did not provide the consent.”

In its

Petition, Assurance outlined its process for obtaining prior express consent from consumers, as

follows:

Consumers seeking quotes through one of [Assurance’s] web

sites…are first required to answer questions to provide information

relevant to the formulation of a needs assessment. This information

includes the customer’s name, telephone number…address, and

[originating IP-address]…At the final step, in order to receive an

online quote, the consumer sees, immediately above the submit or

“get my quote” button, the statement, “By Clicking View My Quote,

I agree to the below consents.” Adjacent to that button, the

consumer sees the following:

Petition at 1 (internal citation omitted).

Petition at 2-3.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 4 of 41

Typically, a consumer is not required to click on the “partner companies” hyperlink, nor

the hyperlinks for the “Terms and Conditions” or “Privacy Policy,” in order to click on the “View

My Quote” button. If a discerning consumer clicks on the link for “partner companies,” Assurance

redirects the consumer to a separate webpage,

wherein Assurance lists over 2,100 company

names.

By simply requesting an insurance quote from Assurance via a web inquiry, Assurance

has opened the floodgates for an unwitting consumer to receive thousands upon thousands of

robocalls, emails, or text messages from not only Assurance and “its agents, representatives and

affiliates” (whoever they are), but “other insurance companies or their agents” (whoever they are),

as well as the 2,100+ companies.

In reviewing the list of Assurance “partner companies,” it is readily apparent that not all of

these companies sell insurance products. Without performing an exhaustive internet search of all

2,100+ names, it appears that the list of partner companies includes businesses that sell automobile

warranties or service contracts, solar panels, digital advertising, and debt relief services, to name

a few. Interestingly enough, the list also appears to include lead generation and marketing

companies, as well as companies with wholly generic names, such as ‘American,’ ‘Builders,’

‘Electric,’ ‘Erie,’ ‘Fabric,’ ‘Facility,’ ‘Federal,’ ‘Inc.,’ and ‘LLC,’ to name a few. One can only

speculate as to why such a list would contain such generic names.

https://assurance.com/tcpa-partner-companies (accessed March 28, 2023).

See State AG Reply Comment - Exhibit 1, attached.

See State of Ohio v. Aaron Michael Jones, et al., 2:22-cv-02700-ALM-KAJ (S.D.Oh. 2022), Complaint,

7/7/2022 at ¶ 69 (alleging that when a VoIP provider of an illegal robocaller had to respond to an ITG

traceback request, the robocaller needed to “buy some time” before responding in order to add “auto

services” language to the list of opt-in websites in the terms and conditions).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 5 of 41

Assurance’s business practice is not an anomaly. Telemarketers (and some voice service

providers

) typically rely on the purported consent provided through data brokers, bots, or

weblinks on websites. Various parties create marketing websites with consent forms and then sell

the data (i.e., names and phone numbers) to intermediary ‘aggregators,’ who compile the lead data

from multiple website publishers and then sell the data to other aggregators, and so on, until the

telemarketers purchase the leads for solicitation purposes.

Multiple filers submitted comments

into the record in response to Assurance’s Petition, providing examples and greater explanation of

these practices.

See Order, In the Matter of Urth Access, LLC, File No. EB-TCD-22-00034232, December 8, 2022, at 6-

7, ¶¶ 15-16 (Urth Access, a voice service provider sanctioned by the Commission, claimed, in response to

a Traceback, that its customers obtained consent for student loan robocalls. Urth Access provided the

Traceback group with purported consent logs that included website addresses through which the illegal

robocallers captured the called party’s consent. However, the Commission recognized that none of the

websites had any connection to student loan assistance, but rather, concerned health insurance

products/services. The Commission also recognized that the consent logs failed to provide adequate

disclosure that would constitute valid consent, as required by the Commission’s rules. The websites

included TCPA consent disclosures whereby the consumer agreed to receive robocalls from “marketing

partners.” These marketing partners were only visible to the consumer if the consumer clicked on a specific

hyperlink to a second website that contained the names of 5,329 entities.)

See generally “Follow the Lead” Workshop, Staff Perspective (Sept. 2016) at Staff Perspective: "Follow

the Lead" workshop - September 2016 (ftc.gov).

See, e.g., Letter from Timothy J. Sostrin, Keogh Law, to Marlene Dortch, Federal Commc’ns Comm’n,

CG Docket No. 02-278 (Aug. 12, 2020); Reply Comments of James Shelton in Opposition to Petition for

Expedited Declaratory Ruling filed by Assurance IQ, LLC, CG Docket No. 02-278 (filed July 6, 2020);

Reply Comments of Joe Shields on the Assurance IQ LL Petition for Expedited Declaratory Ruling, CG

Docket No. 02-278 (filed July 6, 2020); Comments of ZipDX LLC, CG Docket No. 02-278 (filed May 28,

2020); Letter from National Consumer Law Center, et al. to Marlene Dortch, Federal Commc’ns Comm’n,

CG Docket No. 02-278 (Aug. 12, 2020); Letter from National Consumer Law Center, et al. to Marlene

Dortch, Federal Commc’ns Comm’n (Oct. 4, 2022).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 6 of 41

B. The Commission’s Proposed Solution and Requests for Comment

In the March 2023 FNPRM, the Commission proposes to amend 47 C.F.R. Section

64.1200(f)(9) by adding the below-emphasized language to the current rule:

The term prior express written consent means an agreement, in

writing, bearing the signature of the person called that clearly

authorizes the seller to deliver or cause to be delivered to the person

called advertisements or telemarketing messages using an automatic

telephone dialing system or an artificial or prerecorded voice, and

the telephone number to which the signatory authorizes such

advertisements or telemarketing messages to be delivered.

Prior express written consent for a call or text may be to a single

entity, or to multiple entities logically and topically associated. If

the prior express written consent is to multiple entities, the entire

list of entities to which the consumer is giving consent must be

clearly and conspicuously displayed to the consumer at the time

consent is requested. To be clearly and conspicuously displayed,

the list must, at a minimum, be displayed on the same web page

where the consumer gives consent.

In addition to comments on the proposed language set forth above, and whether or not it

will “clarify consent” or “help to eliminate illegal text messages and calls,” the Commission seeks

comment on alternatives to the proposed language that would better protect consumers from the

harms of illegal robocalls or text messages.

The Commission also seeks comment on the

principle that prior express consent to receive robocalls or text messages must be made directly to

one entity at a time.

The Commission additionally asks a series of questions regarding how its proposed new

language would affect consumer use of comparison-shopping websites. First, it requests

comments on how it can ensure consumers “can consent to obtain further information from the

March 2023 FNPRM at 34, Appendix C; compare 47 CFR § 64.1200(f)(9).

March 2023 FNPRM at 23, ¶¶ 61 and 62.

Id. at 23, ¶ 61.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 7 of 41

site without receiving numerous calls and texts from unrelated companies.” Second, it requests

that commenters discuss whether the new language would limit the value of comparison-shopping

sites to consumers. Third, the Commission asks whether alternatives to the proposal exist that

would better protect consumers from unwanted robocalls and texts that may result from use of

comparison-shopping websites.

The undersigned State AGs support the Commission’s consistent and long history of

requiring that prior express written consent for telemarketing be directly between a specific

consumer and one specific seller. Based upon our understanding of the TCPA, the Code of Federal

Regulations (“Code”), and the Commission’s previous orders, there is no “lead generator

loophole.” Rather, those who profit from the robocall ecosystem are ignoring established law.

As such, the State AGs respectfully suggest that in lieu of amending the current language

of Section 64.1200(f)(9) as proposed, the Commission instead clarify that the existing

requirements for prior express written consent to receive robocalls and texts are in line with the

principle that such consent must be made directly to one entity at a time. By doing so, the

Commission will better protect consumers and avoid likely disputes over interpretation of the term

“logically and topically associated.”

The State AGs also believe that contrary to the opening comments offered by members of

the telemarketing industry, the Commission’s proposed new language permitting consumer

consent to apply to more than one seller at a time is not necessary for consumers to continue to

enjoy the benefits of comparison-shopping websites. Rather, as addressed in Section C (iii) below,

within the structure of the current rule, these websites can make slight shifts to how information is

Id.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 8 of 41

displayed in a way that continues to provide consumers the benefit of comparison, without

subjecting them to unwanted robocalls and texts.

C. Discussion

(i) The Current Rules Require Consent to One Seller at a Time

In 1991, Congress passed the TCPA to address consumer outrage “over the proliferation

of intrusive, nuisance calls to their homes from telemarketers.”

The TCPA provides that it is

unlawful to make certain calls and texts

using an automatic telephone dialing system

or an

artificial or prerecorded voice.

In addition, the TCPA vests the Commission with authority to

promulgate rules to implement this prohibition.

Pursuant to this authority, the Commission

determined that autodialed, prerecorded, or artificially voiced calls that introduce an advertisement

or constitute telemarketing are illegal unless the called party has given “prior express written

consent” to be called.

The Code provides that the called party must provide permission to the seller. The Code

defines “Seller” as “the person or entity on whose behalf a telephone call or message is initiated

for the purpose of encouraging the purchase or rental of, or investment in, property, goods, or

Public Law 102-243, 105 Stat 2394 (Dec. 20, 1991) at Section 2 (6).

In 2003, the Commission clarified that “calls” include text messages to wireless numbers. 2003 TCPA

Order, 18 FCC Record at 14115, para. 165.

In Facebook v. Duguid, 141 S.Ct. 1163, 1171 (2021), the Supreme Court clarified that “a necessary

feature of an autodialer under § 227(a)(1)(A) is the capacity to use a random or sequential number generator

to either store or produce phone numbers to be called.”

See 47 U.S.C. § 227(b)(1)(A) and (B).

47 U.S.C. 227(b)(2).

47 C.F.R. 64.1200(a)(2).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 9 of 41

services, which is transmitted to any person.”

Furthermore, the Code defines “prior express

written consent,” in relevant part, as “an agreement, in writing, bearing the signature of the person

called that clearly authorizes the seller to deliver or cause to be delivered to the person called

advertisements or telemarketing messages using…an artificial or prerecorded voice… .”

Hence,

for advertising and telemarketing robocalls, the Code establishes that there must be express written

consent by the called party to the seller.

Next, the Code delineates the requirements for the written agreement as follows:

(i) The written agreement shall include a clear and

conspicuous disclosure informing the person signing that:

(A) By executing the agreement, such person authorizes

the seller to deliver or cause to be delivered to the signatory

telemarketing calls using an automatic telephone dialing

system or an artificial or prerecorded voice …

Courts interpret “clear and conspicuous” to mean a notice that would be apparent to the reasonable

consumer, separate from advertising copy or other disclosures.

The plain language of the existing rules makes clear that the Commission already intended

for consent under the TCPA to be directly between a specific consumer and a specific seller. The

Commission’s orders adopting these rules confirm this interpretation. For example, in 1995, in

one of the first Commission orders implementing the TCPA, the Commission observed that

47 C.F.R. §64.1200(f)(10).

47 C.F.R. § 64.1200(f)(9) (emphasis added).

Id. (emphasis added).

See Lundbom v. Schwan’s Home Service, Inc., 2020 WL 2736419 (D. Or. 2020); Satterfield v. Simon &

Schuster, Inc., 569 F.3d 946, 954-955 (9th Cir. 2009); Karpilovsky v. All Web Leads, Inc., No 17 C 1307,

2018 WL 3108884, *5 (N.D. Ill. 2018).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 10 of 41

although the statute does not define “express permission” or “invitation” from a consumer to

permit telemarketing calls, Congress did not intend to allow telephone solicitation calls unless the

called party (a) clearly stated that the telemarketer may call, and (b) clearly expressed an

understanding that the telemarketer’s subsequent calls will be made for the purpose of encouraging

the purchase of goods or services.

Also, in its 2012 TCPA Order,

the Commission declared it would “maximize consistency

with the Federal Trade Commission’s (“FTC”) analogous Telemarketing Sales Rule (“TSR”)”

by adopting its current rules on consent:

Consistent with the FTC’s TSR, [the Commission concludes] that a

consumer’s written consent to receive telemarketing robocalls must

be signed and sufficient to show that the consumer: (1) received

‘clear and conspicuous disclosure’ of the consequences of providing

the requested consent, i.e., that the consumer will receive future

calls that deliver prerecorded messages by or on behalf of a

specific seller; and (2) having received this information, agrees

unambiguously to receive such calls at a telephone number the

consumer designates.

In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991,

Memorandum Opinion and Order, 10 FCC Record 12391, 12396 (Aug. 1995) at ¶11 (emphasis added).

Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, CG Docket No.

02-278, 27 FCC Record 1830, February 15, 2012 (“2012 TCPA Order”).

https://docs.fcc.gov/public/attachments/FCC-12-21A1_Rcd.pdf

2012 TCPA Order, at 1831, ¶ 1.

Id. at 1844, ¶ 33 (emphasis added).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 11 of 41

The TSR also requires the seller to obtain prior express consent from the called party.

When the FTC amended the TSR in 2008 to prohibit telemarketing calls delivering prerecorded

messages without a consumer’s express written agreement to receive such calls, the FTC

responded to consumer comments expressing concern for their contact information being shared

with affiliates or other companies. The FTC unequivocally stated that a “consumer’s agreement

with a seller to receive calls delivering prerecorded messages is non-transferrable. Any party

other than that particular seller must negotiate its own agreement with the consumer to accept

calls delivering prerecorded messages. Prerecorded calls placed to a consumer on the [National

DNC Registry] by some third party that does not have its own agreement with the consumer would

violate the TSR.”

Like the amended TSR, the TCPA and the Code allow sellers and

telemarketers to call any person whose number has been entered on the National DNC Registry if

that person has given his or her “prior express invitation or permission” to call, in writing and

signed.

Consequently, the so-called “loophole” is just a figment of the lead generation industry’s

See 16 C.F.R. § 310.4(b)(1)(v)(A) (in order to initiate any outbound telephone calls that deliver

prerecorded messages to induce the purchase of goods or services, the seller must obtain an express, written

agreement from the called party).

See Federal Register, Vol. 73, No. 169, August 29, 2008, at 51182 (emphasis added);

https://www.ftc.gov/business-guidance/resources/complying-telemarketing-sales-

rule#prerecordedmessages. (“Does a consumer’s written agreement to receive prerecorded message

calls from a seller permit others, such as the seller’s affiliates or marketing partners, to place such

calls? No. The TSR requires that the written agreement identify the single “specific seller” authorized to

deliver prerecorded messages. The authorization does not extend to other sellers, such as affiliates,

marketing partners, or others. May a seller obtain a consumer’s written permission to receive

prerecorded messages from a third-party, such as a lead generator? No. The TSR requires the seller

to obtain permission directly from the recipient of the call. The seller cannot rely on third parties to obtain

permission.”)

47 CFR 1200(c)(2)(ii) (emphasis added); see also, Report to Congress Pursuant to the Do No Call

Implementation Act on Regulatory Coordination in Federal Telemarketing Laws Submitted by The Federal

Trade Commission at 19 (“Like the amended TSR, the revised TCPA Regulations allow sellers and

telemarketers to call any person whose number has been entered on the National Do Not Call Registry if

that person has given his or her ‘prior express invitation or permission’ to call, in writing and signed.”).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 12 of 41

collective imagination. The State AGs respectfully submit that consent under the TCPA is between

one specific consumer and one specific seller.

In 2015, the Commission further put the consumer in command by clarifying that “a called

party may revoke consent at any time and through any reasonable means. A caller may not limit

the manner in which revocation may occur.”

To allow third parties to gather consent would

effectively limit the manner in which consumers who seek to revoke consent can do so. Consumers

would be forced to first receive robocalls from a seller and then revoke consent individually to

each seller. Third-party lead generators that gather consent for multiple sellers do not generally

maintain a relationship with the sellers past the sale of consumer consent data, and thus, they

cannot reliably transmit a revocation of consent from a consumer.

As a result, if a consumer initially consents to receive robocalls through a third-party lead

generator, or if fabricated consent is fraudulently provided to a third-party lead generator, then the

consumer cannot subsequently revoke consent through the lead generator and is likely to receive

an ongoing barrage of robocalls from sellers who purchase the consumer’s information.

Consumers who, for example, wish to receive information on mortgage rates do not need or desire

mortgage related solicitations in perpetuity. Rather, in most instances, the consumer will either

refinance or purchase a home, or they will change their mind after some time and no longer wish

to receive solicitations.

However, when third-party lead generators collect and sell a consumer’s consent, the

consumer cannot effectively revoke consent after the consumer’s need for mortgage information

has passed. Rather, each time the lead generator sells the consumer’s information, and a seller

Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991; American

Association of Healthcare Administrative Management, Petition for Expedited Declaratory Ruling and

Exemption; et al, FCC 15-72, ¶ 48. https://docs.fcc.gov/public/attachments/FCC-15-72A1_Rcd.pdf.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 13 of 41

calls, the consumer must answer the unwanted robocall and revoke consent to the individual seller.

This is another important reason why the Commission’s rules should not be amended to permit

web-based consent from one consumer to apply to multiple sellers, even sellers of logically or

topically related services.

The March 2023 FNPRM suggests a clear line in the sand in its proposal to “ban the

practice of obtaining a single consumer consent as grounds for delivering calls and text messages

from multiple marketers on subjects beyond the scope of the original consent.” However, the State

AGs respectfully submit that the Commission’s proposed solution will not achieve this result.

Under the Commission’s proposed amendments, multiple entities would be legally permitted to

rely on the consent provided to another, totally separate entity. Instead of hyperlinks to separate

websites, it is likely that hundreds, if not thousands, of so-called ‘marketing partner’ names will

be crammed onto consent pages. Sellers, telemarketers, and voice service providers will most

likely declare such practice is ‘clear and conspicuous’ because all the consumer has to do to see

the fine print is to click on the magnifying glass icon to increase the size of the font on the computer

screen.

In summary, the proposed amendment in Appendix C of the March 2023 FNPRM will not

achieve the intended purpose, but it will open doors to new tricks and gimmicks. Instead, the

Commission should simply clarify and reiterate that consent under the TCPA is between one

specific consumer and one specific seller. If another seller wants consent to send robocalls to that

consumer, then that other seller should independently obtain consent—no more hyperlinks, no

more ‘marketing partners,’ and no more confusion.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 14 of 41

(ii) The Commission Should Confirm Compliance with the Federal E-Sign Act

The Code also requires the written consent for telemarketing to comply with the federal

Electronic Signatures in Global and National Commerce Act (“E-Sign Act”).

The Code states

that the called party’s “signature shall include an electronic or digital form of signature, to the

extent that such form of signature is recognized as a valid signature under applicable federal law

or state contract law.”

The E-Sign Act enables the validity and enforceability of electronic

signatures. Pursuant to the E-Sign Act, an “electronic signature means an electronic sound,

symbol, or process, attached to or logically associated with a contract or other record and executed

or adopted by a person with the intent to sign the record.”

Hence, basic E-Sign law requires that for every agreement made electronically, there be

four separate elements to constitute consent: (1) an electronic sound or process, such as the click

of a mouse; (2) that is attached to or logically associated with a contract or agreement; (3) executed

or adopted by the person; (4) with the intent to sign the agreement. Simply put, one cannot intend

to sign an agreement when one does not know what the agreement is. Consequently, extending

permission for telemarketing to entities and for services that are not specifically identified on the

webpage where the consumer clicks to give permission to a specific seller does not provide the

requisite intent.

In the Commission’s 2012 TCPA Order, the Commission concluded that “consent obtained

in compliance with the E-Sign Act will satisfy the requirements of its revised rule, including

permission obtained via an email, website form, text message, telephone keypress, or voice

15 U.S.C. § 7001, et seq.

47 C.F.R. § 64.1200(f)(9)(ii).

15 U.S.C. § 7006(5).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 15 of 41

recording.”

The Commission further concluded that “[a]llowing documentation of written

consent under the E-Sign Act [would] minimize the costs and burdens of acquiring prior express

written consent for autodialed or prerecorded telemarketing calls while protecting the privacy

interests of consumers.”

In addition to restricting prior written consent for telemarketing to one specific seller,

current Commission rules require the consent to be in writing and comply with federal E-Sign Act

requirements. Accordingly, the undersigned State AGs request that the Commission reiterate that

practices such as those employed by Assurance, as described above, violate Commission rules.

Claims by “marketing partners” (listed on a separate webpage or website) that a consumer’s mouse

click provided valid written consent for telemarketing are invalid. Moreover, because the E-Sign

Act requires that the agreement be presented in writing,

there is no authority for concocting oral

consent during a robocall.

(iii) Reaffirming that the Current Rule Already Requires One Consent to One

Seller at a Time Will Not Limit the Value of Comparison- Shopping Sites to

Consumers.

As mentioned above, the Commission also requested the following input concerning its

proposed modification of its rule regarding preexisting consumer consent to telemarketing calls

and texts to allow one consent to apply to multiple sellers:

Consumers may find comparison shopping websites helpful; how

can we ensure that they can consent to obtain further information

from the site without receiving numerous calls and texts from

unrelated companies? Commenters should discuss whether our

Small Entity Compliance Guide, CG Docket No. 02-278, May 13, 2013 (“FCC Compliance Guide”), at

p. 4; citing 2012 TCPA Order at 27 FCC Record 1830, 1844, ¶ 34.

FCC Compliance Guide, at 4.

15 U.S.C. § 7001(c)(1).

15 U.S.C. § 7001(c)(6).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 16 of 41

proposal would limit the value of comparison-shopping sites to

consumers.

In the opening comment period, several commenters that support or operate comparison-

shopping websites supported modifying the rule to expand consent to multiple sellers, arguing that

requiring one consent per consumer would reduce access to and increase the cost of credit, deprive

consumers of choice, and stifle competition.

For example, Lending Tree represents:

[The] proposal will harm consumers, consumer welfare, and the

competition that comparison-shopping websites promote among

multiple providers and sellers. Such a limitation undermines the

very reason that a consumer seeks out and visits a comparison-

shopping website, which is to obtain simultaneous offers from

multiple, competing sellers and providers, rather than having to shop

from seller to seller on their own.”

Similarly, Drips, which describes itself as a “conversational outreach platform that helps

compliant businesses set appointments with consumers who have existing business relationships

or provided written consent to be contacted for specific purposes,”

claims:

Suggesting that consent should only be able to be made in a 1:1

fashion is an oversimplification to a nuanced problem. This would

effectively kill all comparison-shopping websites, consumer choice,

and online marketplaces as we know it.

March 2023 FNPRM at 23, ¶61.

See e.g., Comments of Lending Tree, LLC, CG Docket No. 02-278 (May 8, 2023) (“Lending Tree

Comments”); Letter from Drips, CG Docket No. 02-278 (May 8, 2023) (“Drips Letter”); Letter from

Online Lenders Alliance, CG Docket No. 02-278 (May 8, 2023).

Lending Tree Comments at 12.

Drips Letter at 1.

Id. at 3.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 17 of 41

The State AGs disagree that enforcing the existing rule would harm consumer welfare and

“effectively kill all comparison-shopping websites.” Comparison-shopping websites such as

Lending Tree provide a service to consumers by gathering potential credit options in one place,

but they do not perform a hard credit pull and do not provide firm offers of credit. As a result,

consent is not necessary for their services to be offered and any related benefit to be rendered.

Rather, consumers could use these services and then select the lender or lenders they wish to hear

from individually. It is not necessary that a consumer be required to agree to receive robocalls or

robotexts from multiple, potentially hundreds of other lenders in order for them to access the

services of comparison-shopping websites.

Indeed, it is permissible under the current rules for a comparison-shopping site to collect

express consent from individual sellers for telemarketing calls or texts on their websites. The

website simply must clearly and conspicuously disclose the names of the sellers that may contact

the consumer and ask the consumer to consent specifically to each seller from which they agree to

receive calls or texts. The current rule does not prevent sellers from obtaining express consent.

Therefore, the current rule does not undercut the business model insofar as that model relies on

sellers obtaining specific consent from a consumer on a one-by-one basis.

In short, enforcing the rules to require pre-existing written consent to call or text a

consumer for purposes of telemarketing from one consumer to one seller at a time will not reduce

consumer access to credit, deprive consumers of choice, or stifle competition in the comparison-

shopping industry. Rather, enforcing the current rule better protects consumers by requiring that

they proactively consent to receiving further information from other companies. The State AGs

therefore ask the Commission to reject commenter claims that enforcing the current rule would

impair the value of comparison-shopping sites to consumers.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 18 of 41

III. TEXT MESSAGES

A. The Illegal Text Problem

With the advent of mobile phones, the speed and the ease with which we communicate

with others has increased exponentially. This increased speed creates circumstances that make

consumers more vulnerable to robotext fraud. Consumers rely upon their mobile phones to receive

communications that are characteristically short, but often important. As such, it is easier for bad

actors to disguise their identities through a text message, in comparison to an illegal robocall or

phishing e-mail. During a phone call or while reading an e-mail, the would-be victim has

additional time to identify the scam, whereas this is not so with a short text message containing a

malicious link. Simply by tapping (inadvertently or purposefully) the link in a text, consumers

may expose their phones to malware and viruses. Given the amount of personal information

contained on our cellular phones, the potential financial and personal privacy harms are vast.

The evidence already before the Commission supports a need to enact effective rules to

address the continuing threat scam robotexts pose to consumers. As the Commission recognized,

the number of spam text messages that wireless providers blocked grew ten times, from an

estimated 1.4 billion in 2015 to 14 billion in 2020.

In addition, consumers have reported $231

million in losses from text message scams in the first three quarters of 2022, which is greater than

the losses reported in 2020 and 2021 combined.

March 2023 FNPRM at 3, ¶ 6.

Id. at 4, ¶ 6.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 19 of 41

To curb the onslaught of illegal robotexts, the Commission seeks comment on whether it

should adopt processes similar to those in place for illegal robocalls. Specifically, the Commission

proposes, inter alia, to require terminating providers to block texts from a sender after the

providers are on notice from the Commission that the sender is sending illegal texts, and to extend

the National Do-Not-Call (“DNC”) Registry’s protections to text messages.

The State AGs

commend the Commission’s attention to the particular issue of illegal robotexts, distinct from the

issue of illegal robocalls, and support the Commission’s efforts to review, clarify, and refine rules

that aim to enhance protections for consumers and honor their requests not to be bombarded by

illegal robotexts.

B. Blocking Texts upon Commission Notification

In the March 2023 FNPRM, the Commission proposes to “require terminating mobile

wireless providers to investigate and potentially block texts from a sender after they are on notice

from the Commission that the sender is transmitting suspected illegal texts, similar to [the

Commission’s] requirement for gateway providers with respect to voice calls.”

Based on the

Commission’s proposal, the State AGs presume that the Commission’s Enforcement Bureau

would issue an official notice of suspected illegal texts to a terminating mobile wireless provider

(“terminating provider”).

The terminating provider would then promptly investigate the

identified text(s) and either block the texts and substantially similar texts on an ongoing basis or

Id. at 3, ¶ 4.

Id. at 20, ¶ 50.

Id. at 20, ¶ 52.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 20 of 41

respond to the Commission that the terminating provider has a reasonable basis for concluding that

the identified texts are not illegal.

To begin, the State AGs support the principle that all entities in the wireless messaging

ecosystem have an obligation to do their part to preserve the trust in, and utility of, messaging

services.

This includes those providers who ultimately deliver illegal texts to consumers.

However, because State AGs, along with the Commission, also understand that the messaging and

voice ecosystems each have significantly different infrastructures,

we are mindful that

comparable success in mitigating illegal robotexts may not precisely align with the playbook that

has been so effectively devised and refined by the Commission to mitigate illegal robocalls.

Therefore, to the extent that the Commission has determined that extending the robocall

blocking protocols to robotexts will actually bring a measurable benefit to consumers across the

country in preventing fraud, the State AGs support such a proposal. The State AGs further urge

the Commission to continue exploring ways in which rules specific to the unique infrastructure,

players, and technology of messaging and robotexting can be proposed and deployed to effectively

and efficiently mitigate the continuing, burgeoning threat targeting our consumers.

Id.

See CTIA, Messaging Principles and Best Practices, https://www.ctia.org/the-wireless-

industry/industry-commitments/messaging-interoperability-sms-mms (last visited May 2, 2023)

(enumerating a set of voluntary best practices developed in July 2019 by CTIA, the messaging industry

association, and its member companies throughout the wireless messaging ecosystem).

Reply Comments of Fifty-One (51) State Attorneys General, Targeting and Eliminating Unlawful Text

Messages at 4, CG Docket No. 21-402 (Dec. 9, 2022).

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 21 of 41

C. Clarifying Do-Not-Call Protections for Text Messages

To the extent that it may be unclear, the Commission proposes to “clarify that the National

DNC Registry protections apply to text messages as well as voice calls and to codify this

clarification in [the Commission’s] rules.”

Previously, the Commission has stated that “text

messages” are “calls” for TCPA purposes and has taken the position that the National DNC

Registry protects consumers from unwanted marketing text messages.

However, the

Commission has not explicitly included text messages in the codified DNC rules.

As the Commission recognized, the National DNC Registry has been operational for almost

twenty years and currently protects over 246 million telephone numbers from telemarketing sales

calls.

As with our respective state DNC registries, the National DNC Registry is popular among

consumers, as it provides a means through which consumers can exercise a modicum of control

over the marketing telecommunications they choose to receive.

The State AGs support the Commission’s proposal to clarify that the National DNC

Registry protections will apply to marketing text messages. Such clarification is a common-sense

approach to eliminate any potential confusion in the industry and has the added benefit of

providing protection to consumers regardless of whether the texting party utilizes an autodialer.

March 2023 FNPRM at 21, ¶ 55.

Id.

Id. at 22, ¶ 57.

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 22 of 41

IV. CONCLUSION

The undersigned State AGs thank the Commission for the opportunity to present these

comments in this proceeding and reaffirm our commitment to work with the Commission in

combatting illegal robocalls and text messages. We respectfully urge the Commission to take this

opportunity to shut down these unreliable and illegal methods of purportedly obtaining consent

from consumers for marketing robocalls and texts. To that end, the State AGs recommend the

Commission issue an Order that clarifies and confirms that its existing rules concerning “prior

express written consent” contemplate consent between a specific consumer and one specific seller.

This measure, as well as the other recommended measures set forth above, will ultimately better

protect consumers from unwanted robocalls and text messages, which is a goal that the

Commission and the State AGs collectively share.

BY 28 STATE ATTORNEYS GENERAL:

STEVE MARSHALL TREG TAYLOR

Attorney General of Alabama Attorney General of Alaska

KRISTIN K. MAYES ROB BONTA

Attorney General of Arizona Attorney General of California

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 23 of 41

PHILIP J. WEISER WILLIAM TONG

Attorney General of Colorado Attorney General of Connecticut

BRIAN L. SHWALB KWAME RAOUL

Attorney General of District of Columbia Attorney General of Illinois

AARON M. FREY ANTHONY G. BROWN

Attorney General of Maine Attorney General of Maryland

ANDREA JOY CAMPBELL DANA NESSEL

Attorney General of Massachusetts Attorney General of Michigan

KEITH ELLISON LYNN FITCH

Attorney General of Minnesota Attorney General of Mississippi

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 24 of 41

MATTHEW J. PLATKIN JOSH STEIN

Attorney General of New Jersey Attorney General of North Carolina

DREW H. WRIGLEY DAVE YOST

Attorney General of North Dakota Attorney General of Ohio

GENTNER DRUMMOND ELLEN F. ROSENBLUM

Attorney General of Oklahoma Attorney General of Oregon

MICHELLE A. HENRY ALAN WILSON

Attorney General of Pennsylvania Attorney General of South Carolina

JONATHAN SKRMETTI CHARITY R. CLARK

Attorney General of Tennessee Attorney General of Vermont

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 25 of 41

JASON MIYARES BOB FERGUSON

Attorney General of Virginia Attorney General of Washington

Attorney General of Wyoming

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 26 of 41

State AG Reply Comment – Exhibit 1

1st Century

21st Century

21st Century Insurance

2insure4less

5 Star Auto Protection

7Made Media

AAA Auto Warranty

AAA Insurance Co.

AA Auto Protect

AABCO

AA Media Inc

AARP

ABCLeads

A&B Insurance and Financial

Abrazo Health

Absolute Health Agents

ACA Express

Acceptance

Acceptance Insurance

Access Insurance

AccordantMedia

Accuquote

ACE Global Marketing LLC

ACE Solutions

Acme

Acordia

Acquisition Tech

Acquisition Technologies

ACSC

Adexec Services

Admaric Insurance Agency

AdMediary

Admiral Life

AdoptAContractor

Adrea Rubin

Adrian Adams Agency

Adsparkx Digital

ADT

ADT Solar

Advance Consultants LLC

Advanced Vehicle Protection Center

Advantra

Advocate Health

Advocator Group

Aegis First

Aegis Security

Aegon US Holding Corp.

Aetna

A & E Vehicle Services

Affinity Health Plan

Affirmative

Affordable Healthcare Partners

Affordable Health Insurance Group

Affordable Insurance Group Inc.

Affordable Senior Health Solutions

AFLAC

AGA

Agency Incline

AgentCubed Marketplace

Agent Insider

Agent Marketing Partners

Agentra Healthcare

AHCP

AHH

AHIA

AHIX

AIB

AIG

AIG Direct

AIO

AIP

AIS

AIU

AIU Insurance

Alfa Insurance

Alfonzo Insurance Allstate Agency

Aliera Healthcare

All Access Health Insurance

All American Health Agency

Allcare United

Allcare United LLC

AllDigitalPromotions

All Digital Promotions

Allegiant Group

Alliance

Alliance 321

Alliance and Associates

Alliance & Associates

Alliance Insurance

Alliance National Health

Allianz

Allied

Allied Health

Allied Health Insurance Associates

Allied Health Insurance Associates LLC

Allied Insurance

Allied Insurance Partners

Allina Health

All Nation

All Risk

Allstate

Allstate County Mutual

Allstate Indemnity

Allstate Insurance

AllWebLeads

All Web Leads

Alpha Benefits Center

Alphatech Resource Holdings s.r.o

Alpine Digital Group, Inc.

America Auto Care

America Direct

American

American Adventure Insurance

American Alliance

American Automobile Insurance

American Automotive Alliance, LLC

American Banks

American Benefits

American Benefits Group

American Casualty

American Commerce Insurance Company

American Continental

American Deposit Insurance

American Direct Business Insurance

American Economy

American Empire Insurance

American Family

American Family Insurance

American Family Mutual

American Fidelity Corp.

American Financial

American General

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 27 of 41

American Health & Life Associates

American Health Marketplace

American Health Plans

American Health Reform Solutions

American Health Solutions

American Health Underwriters

American Home Assurance

American Income Life

American Income Life Insurance Company

American Income Life Insurance Company Family

American Insurance

American Insurance Agencies

American Insurance Agencies Direct

American Insurance Agencies Direct Inc.

American Insurance Company

American Insurance Organization

American Insurance Organization, LLC

American International

American International Ins

American International Pacific

American International South

American Life & Health

American Manufacturers

American Mayflower Insurance

American Motorists Insurance

American National

American National Insurance

American National Insurance Co

American National Property and Casualty

American Premier

American Premier Insurance

American Protection Insurance

American Reliable

American Republic

American Republic Insurance Co.

American Savers Plan

American Security Insurance Company

American Select

American Select Health

American Senior Med

American Service Insurance Agency

American Skyline Insurance Company

American Spirit Insurance

American Standard

American Standard Insurance - OH

American Standard Insurance - WI

American States

American Workers Insurance Services

Americare

Americare/American Enterprise

Americare Group

America's Health Advisors

Americas Health Brokers

America's Health Care Plan

Americas Health Group

America's Insurance

America's Moneyline, Inc.

America's Trust

America's Trust, Inc.

AmeriChoice

Americo

Amerigroup

AmeriHealth

Amerilife

AmeriLife Group, LLC

Amerilife Marketing Group, LLC

AmeriPlan

Ameriprise

Ameriprise Financial Group

Ameriquote

AmeriSave

Amerisure

Amica

Amica Insurance

AmOne

Angelic Marketing Group

Angelic Marketing Group, LLC

Anhelo Insurance Solutions LLC

Anhelo Insurance Solutions LLC.

ANPAC

Answer Financial

Anthem

Anthem BCBS

Anthem / BCBS

AON

Aon Corp.

APEX Health Plans

API

Apliant

Apollo Insurance Group

Apollo Interactive

Applied General

Aragon Advertising

Aragon Advertising LLC

Arbella

Ardent Health Services

Arizona General

Armed Forces Insurance

Arrowhead

Arrowstar Insurance Center

Art Institute

Assigned Risk

Associated Indemnity

Associated Insurance Managers

Assurance IQ, Inc.

Assurant

Assured Benefits Direct

Assured Health Group LLC

Assured Life

Assure Media

Astonish

Astoria Company

Atlanta Casualty

Atlanta Specialty

Atlantic Auto Protection

Atlantic Blue Media

Atlantic Health

Atlantic Health Advisors

Atlantic Indemnity

Atlantis

Atlantis Health Group

Atomic Leads

Atreus Medicare Group

Austin Mutual

AutoCarenow.com

Auto Club Insurance Company

Auto Insurance Guide

Automobile Association of America

Automobile Club of Southern California

Auto Owners

Auto Protection 1

Auto Protection Club

Auto Repair Network

Auto Repair Protection Services

Auto Service Center

Auto Warranty Savings Center

Avendia

Avendia Management

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 28 of 41

Avenge Digital

Aviva

Avmed

AvMed Inc.

Avomark

AXA

AXA Advisors

AXAD Capital

AXA Insurance Group

Badger Mutual

Balanced Life Agency

Banker's Fidelity

Bankers Hill Insurance

Bankers Life and Casualty

Bankers & Shippers

Bankrate

Bankrate, Inc.

Bankrate Insurance

Banner Life

Bantam Connect

Bartleson Brokers

Bayside

BBRS Group

BCBS

BCBS of Alabama

BCBS of Florida

BCBS of Michigan

BC Group LLC

BE Marketing Solutions Inc.

Benefit Advisors

Benefit Mall

Benefit United LLC

Benepath

Bennett FMO

Bennett Insurance Agency

Best Agency USA

Best Health Options

Best Insurance Group

Bestow

Better Health Alternatives

Better Living Health Services

Better Mortgage Corporation

Beyond Finance, DBA Accredited Debt Relief

BH Insurance Solutions, LLC

Bianco

Black Optek

Blueberry

Blue Choice

Blue Cross

Blue Cross - Anthem

Blue Cross Blue Shield

Blue Cross/Blue Shield Association Companies

Blue Cross of South Carolina

Blue Ink Digital

Bluensure Insurance

Blue Nsure Insurance

Blue Shield of California

Blue Summit

Blue Summit Insurance Solutions

Blue Wing Ads

BMP Insurance

Bold Media Group

Bolt

Bonneville

Boost

Boost Health

Boost Health Insurance

Boston Old Colony

Bravo Health

BridgeNet

BridgeNet Insurance

Bright Health Plan

Bright Health Solutions

Bright Idea Insurance Solutions, Inc.

Brightway

Bristolwest

Bristol West

Brokers Alliance

Brooke Franchise Corporation

Brooke Insurance

Brookstone Financial

BRXTN Digital Media

Budget Family Insurance

Builders

Burial Expense

c0aster

Cal Farm Insurance

Caliber Health Solutions

Caliber Home Loans

Caliber Home Loans, Inc.

California Casualty

California State Automobile Association

Call4SeniorSavings.com

Call Blade

CallCore

CallCore Media

Call Lead Solutions

Call Trader

Call Trader LLC

Cambia

Camden

CAN

CancerInsurance.com

Candid Maven

Capital Auto Protection

Capital Choice

Capital District Physicians Health Plan

Capital Health Advisors Inc.

Capital Health Insurance of America

Carchex

Cardinal Financial Company, Limited Partnership

Care Entrée

CareMore

Caresource

CareZone

Carezone Inc.

CareZone Insurance Services

CarGuard Administration

Carle Clinic Association

Carriers and partner companies include

CarShield

Cascade National Ins

Casualty Assurance

Catholic Financial Life

CDPHP

CDX Consultants

CEGE

Cege Media

Cekirk Insurance

Celtic Insurance

Centene

Centene Corp.

Centennial

Central Bank

Century Benefits

Century Insurance

Certainty Auto Protection

Channel Blend

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 29 of 41

Charter Oak

Chase Insurance Group

Cherry Blitz

Chesapeake

Chicago Insurance

Choice Direct

Choice Health

Choice Insurance

Choice One Health

Choice One Health & Life Agency

Choice Right LLC

Christian Fidelity

Chubb

Church Mutual

Cigna

CIQ

Citation Insurance Company

Citigroup

Citizens

Citizens Disability

Clarendon American Insurance

Clarendon National Insurance

Clean Energy Concepts

Clear Choice Health

Clearcover

ClearLink

Clear One

Click 2 Call Network

Clicks and Clients

Client Consent Medicare

Cloverleaf

CMG Solutions

CNA Insurance

Coastline Insurance Advisors LLC

CO Farm Bureau

Colby Direct

Colonial

Colonial Insurance

Colonial Penn

Combined

Comfortcare Insurance Group

Comfort Care Insurance Group

ComfortCare Insurance Group

Commerce West Insurance Company

Commercial Insurance Center

CommercialInsurance.net

Commercial Marketing Group

Commercial Union

Commonwealth

Communicating for America

CommunityCare

Community Care

Compare.com

CompareInsuranceQuotes

Compare Insurance Quotes

Comparenow

Comparequotes

Comparison Market

Complete Car

Complete Healthcare Direct, LLC

Confie

Connect Health Insurance

Connect Health Insuranceli>

ConnectiCare

Connect Insurance Brands

Connect Life Plans

Connect Life Plansli>

Connect Medicare Advantage

Connect Medicare Advantageli>

Connect Medicare Supplement

Connect Medicare Supplementli>

Connect One Health

Connect Plus

Conseco Life

Consumer Advocacy LLC

Consumer United

Contactability

Continental Casualty

Continental Divide Insurance

Continental Insurance

Continental Life

Conventry

Core Healthcare Solutions

Core Health Solutions

Corner Shop Media

Corner Stone Media

COTO INDUSTRIES LLC

Cotton States Insurance

Cottonwood

Countershot Media

Country Companies

Country Financial

Country Insurance and Financial Services

Countrywide Insurance

Couvillier Advisors

Coventry

Coventry Health Care

Coverage Choice LLC

Coverage One

Coverage One Insurance

Coverage One Insurance Group LLC

Coverage One Insurance Group, LLC

Coverance Insurance Solutions

Coverdell

CoverHound

Covida

CPA Data Solutions LLC

Creative Emarketing

Creative Intellects

Credible Operations, Inc

Credit Union

Crisp-Results

Criterion

Crosspointe

Crosspointe Insurance and Financial Services LLC

Crosspointe Insurance & Financial Services, LLC

CSE

CSE Insurance Group

CS Marketing

Cultur, LLC

CUNA Mutual Group

Dairyland

Dairyland County Mutual Co of TX

Dairyland Insurance

Dakota Fire

Dashers

Datalot

DataMax

Dean Health

Debt.com

Deerbrook

Delphi Financial

Delta Auto Assurance

Delta Auto Protect

Dempsey Advisor

DentalInsurance.com

Depositors Emcasc

Design Benefit Plans

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 30 of 41

Diablo Media

Differential Consulting LLC

Digiline Media

Digital BGA

Digital DBA

Digital Marketing Connection

Digital Market Media

Digital Market Media, Inc.

Digital Media Solutions

Digital Thrive

DIQ Partners

Direct Auto

Direct Choice

Direct General

DirectMail.com

Direct Property & Casualty

Direct Ring Media

Direct Web Advertising

Disability Advisor

Discount Insurance Quotes

Dixie

Dobak Holdings LLC

Doc Auto

Doc Auto Insurance

Doc Insurance

Docktors

DoublePositive

Dozer Health

Draper Agency

Drips

Drivers Protection, LLC

Drobu

DTRIC

Eagle Health

eAmerifamily

East Coast Health Insurance

EasyHealth Insurance Services

easyMedicare.com, an affiliate of e-TeleQuote

Insurance, Inc.

EasyMedicare.com, an affiliate of e-TeleQuote

Insurance, Inc

Ebco General

EC Insurance

Economy Fire & Casualty

Economy Preferred

EDeals Inc

Efinancial

Egis Auto

eHealth

eHealth Insurance

eHealth Insurance Services

eHealthInsurance Services

eHealthInsurance Services, Inc.

Elderplan

Electric

Electric Insurance

Elephant

Elite Health Agency

Elite Health Plus

eMarketing Media Group

EmblemHealth

EMC

Empire

Empire Consumer Services

Empire Health Consultants

Empire Health Solutions

Employers Fire

Empower Brokerage

Encompass

Endurance Warranty Servcies

Enhance Insurance LLC

EnQue Solutions LLC

Enrollment Services Inc.

Ensure

Ensurem

EPath

EPIQ

Epiq Insurance

Equis Financial

Equitable Life

Equita Group

Equita Group Final Expense Services

Erie

Erie Insurance Company

Erie Insurance Exchange

Erie Insurance Group

Erie Insurance Property and Casualty

ESG Insurance LLC

Essential Group LLC

Essential Group, LLC

Esurance

e-Telequote

ETHOS

ETN America Health

Even Financial

Everest Financial & Insurance Services

Everquote

EverQuote, Inc

EverQuote, Inc.

EverQuote ODA

Every Choice Insurance

Exact Match Media

Excel Impact

Excel Impact, LLC

Excelium Group

Excella Benefits, Inc.

Excelling, Inc.

Excellus

Exclusive Digital Media

Explorer

Ezhealthapplcom, Inc.

Fabric

Facility

Fallon Community Health Plan

Family First

Family First Insurance Advisors

Family First Insurance Advisors LLC

Family First Life

Family Health First

Family Health First LLC

Family Heritage Life Insurance Company of

America

Family Life

Family/Rural

Farber Health Advisors

Farm and Ranch

Farm Bureau

Farm Bureau/Farm

Farm Bureau Financial Services

Farmers

Farmers Bank of Kansas City

Farmers Insurance

Farmers Insurance Exchange

Farmers TX County Mutual

Farmers Union

Farmland

Federal

Federated

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 31 of 41

Federated American

Federated Group

Ference Insurance Agency

Festive Health

FFL

Fidelis

Fidelity and Guaranty Life

Fidelity Insurance Company

Fidelity Investments Life

Fidelity Life

Fidelity National

Fidelity Security Life

Figure Lending LLC

Finalexpenseassistant.com

Final Expense Connect

FinanceBox.com

Financial Indemnity

Find Me Health Insurance

Fiorella

Fiorella Insurance Agency

Fire and Casualty Insurance Co of CT

Fireman's Fund

Firemans Fund

First Acceptance Insurance

First American

First American Financial

First Choice Group

First Choice Health

First Family Insurance

First Family Insurance Advisors

First Family Life

First Financial

First General

First Mutual Insurance Group (FMIG)

First National

First Option Health Group

First Preferred Insurance

FirstQuoteHealth.com

Flexquote

Florida Blue

Florida Plan Advisors

Flynn Financial Co

Ford Motor Credit

Forefront Insurance

Foremost

Foremost Insurance

Foresters

Forethought

Formula Marketing & Analytics

Formza

Formza, LLC

Fortegra

Fortegra Insurance

Fortegra Personal Insurance Agency

Fortis

Franklin

Freedom Debt Relief

Freedom health

Freedom National

Freeway

Freeway Insurance

Freeway Insurance Services

Fresh Leads

Fuego Leads

Gainsco

Garland Financial Group

Gaurantee Trust Life

Geber Life

GEICO

Geico Casualty

Geico General Insurance

Geico Indemnity

Geisinger

Geisinger Insurance

Generation Life

Generation Life Insurance

Genworth

Genworth Financial

Gerber

Gerber Life

GetAuto

GetInsured

Getmehealthcare

GetMe Healthcare

GetMeHealthCare.com

GetMeHealthInsurance.com

Get My Life Insured

Get Seen Media

Get Seen Media Group

GHI

Global Equity Finance

Globe Life

Globe Life Insurance Company

Globe Life Insurance Company of New York

GMAC Insurance

GMAC/NGIC

Go Direct Lead Gen

Go Direct Lead Generation, LLC

GoDirect Leads Generation

GoHealth

GoHealth.com

GoHealthInsurance

GoHealthInsurance.com

GoHealth/Norvax

Goji

Golden Care

Golden Rule

Golden Rule Insurance

Golden Rule Insurance Co.

GoMedicare

goMedigap

Good2Go Insurance, Inc.

GotQuotes

Government Employees

Government Employees Insurance

Government Personnel Mutual Life

Grange

Gr Consulting Services

GreatAmerican

Great American

Great Way

Great West

Greene

GRE Harleysville H

GreyPeaks

Grey Peaks

Grinnell Mutual

Group Health Incorporated

Groves Capital, Inc

Guaranteed Benefits

Guaranteed Health

Guaranteed Health Options

Guarantee Trust Life

Guaranty National

Guaranty National Insurance

Guardian

Guardian Healthcare

Guardian Life

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 32 of 41

Guide One

Guide One Insurance

GuidePointe Solutions

Guide to Insure

Gupta Insurance & Financial Service

Halcyon

Hannigan Insurance

Hanover

Hanover Lloyd's Insurance Company

HAP Health Alliance

Happy Days

Harbor Health Advisors

Hartford

Hartford AARP

Hartford Accident and Indemnity

Hartford Casualty Insurance

Hartford Fire & Casualty

Hartford Fire Insurance

Hartford Insurance Co of Illinois

Hartford Insurance Co of the Southeast

Hartford Life

Hartford Omni

Hartford Underwriters Insurance

Harvard Commonwealth Health Plan

Harvard Pilgrim

Haven Life

Hawaii Medical Services Association

Hawkeye Security

HCC Insurance holdings

Health 1nsurance.com

Health Advisors

Health America

Health and Life Associates

Health and Life Plans of America

Health Benefit Center

Health Benefits Center

Health Benefits Direct

Health Benefits One

Health Caddies

Healthcare Advisors

HealthCare Alternatives

Healthcareassistant.com

Healthcare.com

HealthCare.com Insurance Services

Healthcare Direct

HealthCare, Inc.

Healthcare Marketplace

Health Care Service Corp.

Health Care Solutions

HealthCare Solutions

Healthcare Solutions Team

Health Center Marketing

Health Choice One

HealthCompare

HealthCompare Insurance Services, Inc.

Health Connect Insurance

Health Corp USA

HealtheDeals

Health eDeals

Health Exchange Agency

Health First Insurance Agency

Health First Plans

Health Heritage Advisors

Health Insurance Advantage

Health Insurance Advisors

Health Insurance Alliance

Health Insurance Alliance, LLC

Health Insurance for Everyone

Health Insurance Guide

Health Insurance Innovations

Health Insurance Innovations (HII)

HealthInsurance.net

Health Insurance of America

Health Insurance Services

Health Insurance Specialists

HealthIQ

Health IQ

Health I.Q.

Health & Life Advantage

Healthline Care

HealthMarkets

Health Markets

HealthMarkets Insphere

HealthMarkets / Insphere

HealthMarkets Insurance Agency

HealthMatchup

HealthNet

Health Net

Health Network

Health Now New York Inc.

Health Option One

Health Options Team

HealthPartners

Health Partners of Philadelphia Inc.

HealthPlan Advisors

HealthPlanMatchup

HealthPlanOne

Health Plan One

HealthPlan One

HealthPlanOne, LLC

Healthplan Outlook

Health Plans America

Health Plan Services

Health Plans of America

Health Plus

Health Plus of America

HealthPlus of Michigan

Health Plus Solutions

HealthPocket

Health Pocket

HealthPros

Health Providers of America

HealthQuoteInfo.com

Health Savings Group

HealthShare America

HealthShare American

Health Sherpa

Health Solutions One

Healthspire

HealthSpring

Health Team One

Health Works Agency LLCHealth1nsurance.com

Healthy Halo

Heard and Smith

Helmkin Digital

Henry Ford Health System

Heritage

Heritage Health Advisors

Heritage Life Insurance Company

HHA

HIA

HiegPartners

Hieg Partners LLC

Highland Health Direct

Highland Health Direct, LLC.

Highmark

Highmark BCBS

HighPoint

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 33 of 41

High Quality Vehicle Protection

HII

HIIQ

HIP Health Plan

HIP Insurance

Hippo

Hippo Insurance

Hiscox

H&M Advisors

HolaDoctor

Hola Doctor

Homeinsurance.com

Home Insurance King

Homeland Health

Homeland HealthCare

Home Savings

Home Service Companies

Hometown

Hometown Quotes

Home Town Quotes

Horace Mann

Horace Mann Agency

Horizon

Horizon Health Advisors

Hospital Services Association of NEPA

Houstons Health Solutions

How to Enroll

HPO

HSO

HST

HST Enrollment Center

Humana

HyperTarget

Hypertarget Marketing

IAB

iCan Benefit

iCan Benefit Group

Iconic Consultants

ICW

Ideal Concepts

Ideal Concepts, Inc

Ideal Health Benefits

IDS

IFA Auto Insurance

IFA Insurance Company

iFlourish Labs

iFuze Marketing

IGF Ins.

IGF Insurance

Ignitist

IHC

IHC Group

IHC Health Plans

IIS Insurance

iLegacy Insurance

iLife

I Life And Health

IMO

Impact Energy

Impact Media

Imperial Health Group

Imperium Financials

Inavision

Inboxed LLC.

Inc

Independence Blue Cross

Independent Agent

Independent Carriers

Independent Health Association

Independent Health Solutions

Independent Insurance Consultants

Individual Insurance Agencies

Infinity

Infinity Insurance

Infinity National Insurance

Infinity Select Insurance

Infinix

Infinix Media

ING

ING US Life

Innovate Financial Group

Innovation Direct Group

Innovation Group of South Florida

Innovative Financial Group

Innovative Health Group

Innovative Insurance Brokers

Inquire Media

Inside Response

Insphere

Insphere Insurance Solutions

InsuraMatch

Insurance311

Insurance Benefits

Insurance Care Direct

Insurance Central

Insurance.com

Insurance Insight

Insurance Lead Broker, ILB

Insurance Leads

InsuranceLeads.com

Insurance Line One

Insurance Made Easy

Insurance Management Associates

Insurance Medics

Insurance Office of America

InsuranceOnly

InsuranceProz

Insurancequotes

insuranceQuotes.com

InsuranceQuotes, Inc.

Insurance Quotes Now

Insurance Services

Insurance Solutions Direct

Insurance Solutions LLC

InsuranceStep.com

Insure Choice LLC

Insure.com

Insured Street

InsureMe

InsureMe, Inc

Insurify

Insurita

Insur. of Evanston

InsWeb

Integon

Integrated Benefits

Integrated Insurance Solutions

Integriant Ventures Insurance Services

Integrity Health One

Integrity Vehicle Services

IntelliQuote

Interstate

Interstate Brokers of America

Inter Valley Health Plan

Investors Life

IPA Agents

IPA Direct

IPA Family

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 34 of 41

iQuoteX

iWebQuotes

Jackson National Life

J and L Consulting Group

Javier Molina Agency

JB Health and Associates

JCG New Media

Jet Media

JLS

John Deere

John Hancock

Joshua Katyl Allstate

Joyce Emig Insurance Agency Inc

JRC Insurance Group

JSH Marketing

Jupiter

Justified Medical Group

Kaiser

Kaiser Foundation Health Plan

Kaiser Foundation Health Plan, Inc.

Kaiser Foundation Health Plan of Colorado

Kaiser Foundation Health Plan of Georgia, Inc.

Kaiser Foundation Health Plan of the Mid-Atlantic

States, Inc.

Kaiser Foundation Health Plan of the Northwest

Kaiser Foundation Health Plan of Washington

Kaiser Permanente

Kanopy

Kanopy Insurance

Kanopy Insurance Center LLC

Keenan Associates

Kelly Klee Private Insurance

Kelsey-Seybold

Kemper

Kemper Lloyds Insurance

Kentucky Central

KERWYN JONES

Key Insurance Advisors

Keystone

K.F. Agency, Inc.

Kin

Kind Health

Kin Insurance

Knights of Columbus

Koenig Quotes

Kolor Marketing

Komparison

Landmark American Insurance

Lands Health

Laser Marketing

LBCOT Insurance

Leadco

LeadEnvoy

Leader General

Leader Insurance

Leader National

Leader National Insurance

Leader Preferred Insurance

Leader Specialty Insurance

Lead Foundations

Lead Gate Media GmbH

Lead Genesis

Lead Giant

Leading Healthcare

Leadnomics

Lead Origins

Leads Interactive

Lead Trust Media Group

League General

Legacy Insurance Solutions

Legal & General America

Legends United Insurance Agency, Inc

Lemonade Insurance

LendingTree

Lendivia

Level One Health Group

Level Up Funding

LGA

Liberty Automobile Protection

Liberty First Health and Life

Liberty Health

Liberty Health Plan

Liberty Health Professionals

Liberty Insurance Corp

Liberty Mutual

Liberty Mutual Fire Insurance

Liberty Mutual Insurance

Liberty Mutual Insurance Company

Liberty National

Liberty National Life Insurance Company

Liberty Northwest

Liberty Northwest Insurance

LifeInsuranceMatchup

LifeLine Direct

LifeQuotes

Lifetime Healthcare

Lifetime Medicare Advisors

LifeVision of America

LifeWise Health Plan

Lighthouse

Lighthouse Insurance

Lighthouse Insurance Group

LightHouse Insurance Health

Lincoln Benefit Life

Lincoln National

Lion Insurance Group

Liz Byrne USHA

LLC

LNK Insurance Services

LoanBright

LoanDepot.com, LLC, mellohome, and their

corporate parents, affiliates, and partners

LoanSnap, Inc

Lockton Affinity Group

Longevity Alliance

Louisiana Health Services

Loyal American

LPN

LQ Digital

LS Lead Generation

LTC Financial Partners

Lumbermens Mutual

LVOA

Madera Digital

Managed Health Inc.

MAPFRE

MAPFRE Insurance Company

MAPFRE Insurance Company of Florida

MAPFRE U.S.A. Corp. and its affiliates

Marathon

Marchex

Markel American

Martin Financial

Martin's Point

Maryland Casualty

Massachusetts Mutual

Massive&Co

MassMutual

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 35 of 41

Mass Mutual

MassNexus

Mass Nexus

MatchMedia

Match Media Group

Matrix Direct

Matt Rudolph Insurance

Maxim Strategies

Maxxlocal

Mayberry Advisors Insurance Services

Mayo Lab

MCGP International

Mclaren Insurance Solutions

McLaren Insurance Solutions

MedGapDirect

MedGuard Alert, Inc

MediaAlpha

Media Alpha

Media Alpha Exchange

Media Champs

MediaMatchGroup

Media Mix 365

Medica

Medical Card System Inc.

Medical Mutual of Ohio

Medicare10

MedicareAdvantage.com

Medicare Benefits Team

Medicare Connect

Medicare Group USA LLC

Medicare Help Centers

Medicare Providers

MedicareProz

Medicare Solutions

Medigap

Medi-Share

MEGA Life and Health

Mega/Midwest

Mellohome LLC

Memorial Hermann

Mendota

Merastar

Mercury

Mercury Insurance

Mercy

MetLife

Met Life

MetLife Auto and Home

Metromile

Metropolitan Co.

Metropolitan Insurance Co.

Mid Century Insurance

Mid-Continent Casualty

Middlesex Insurance

Midland National

Midland National Life

Midwest Mutual

Mid-West Ntl. Life

Migo Insure

Mikayla Data

Millbank

Millennial Home Lending

Millers Mutual

Milwaukee General

Milwaukee Guardian

Milwaukee Mutual

Minnehoma

Minnesota Mutual

Miro Health Agency

Mission Loans

Mississippi Insurance

Missouri General

MJ Direct

MMI Group

MMM Healthcare Inc.

Mobile Help

Modern Health, LLC

Modern Woodmen of America

Molina

Molina Healthcare Inc.

Montys Health Agency

Mony Group

Mortgage Maven

Mortgage Protection Bureau

Mortgage ProtectionPlus

Mortgage Protection Plus

Morty Inc.

Moss

Moss Affiliate

Moss Affiliate Marketing

Moss Affiliate Marketing Sellers

Motors

Mountain Financial

Mountain Laurel

M Plan Inc.

Mutual Health Partners

Mutual Insurance

Mutual Of Enumclaw

Mutual of New York

Mutual of Omaha

MVA Warranty

MVP

My Health Advisors

My Health Angel

My Health Group

MyHippo

MyInsuranceExpert

My Medicare Ally

National Alliance

National Auto Protection Corp.

National Ben Franklin Insurance

National Better Living Association

National Brokerage

National Brokers of America

National Casualty

National Colonial

National Continental

National Continental Insurance

National Debt Relief

National Disability

National Family Assurance Group, Inc.

National Fire Insurance Company of Hartford

National General

National General Insurance

National General Insurance Company (NGIC)

National Healthcare Market

National Health Connect

National Health Connect, LLC

National Health Hub

National Health Hub, LLC

National Health Insurance

National Health Plans

National Health Plans dba Your Lowest Quote

National Health Solutions

NationalHomeProject

National Income Life Insurance Company

National Indemnity

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 36 of 41

National Insurance

National Merit

National Plan Advisors

National Repair Solutions

National Solar Network

National Surety Corp

National Union Fire Insurance

National Union Fire Insurance of LA

National Union Fire Insurance of PA

National Vehicle Protection Services, Inc.

Nation Health Advisors

Nations Health Group Guide One Insurance

Nations Insurance Solutions

Nations Lending

Nationwide

Nationwide General Insurance

Nationwide Health Advisors

Nationwide Insurance Company

Nationwide Mutual Fire Insurance

Nationwide Mutual Insurance

Nationwide Property and Casualty

Native Media, LLC

Nat'l Farmers Union

Navy Mutual Aid Association

NCWC

Neighborhood Health Plan Inc.

Neilson Financial Services

Neo Ogilvy

Nest Insurance Agency

Net Health Affiliates

NetQuote

New Age Health

New Age Health, Inc.

New Age Health Solutions, Inc.

New American Funding

New England Financial

New Era

Newins

NewQuest

NewStrata

New York Life

New York Life Insurance

New York Life Insurance Group

NexLevelDirect

NextGen

Next Gen

Next Gen Leads

NextGen Leads

NextGen Leads, LLC

Nexus Corporation

Nexus Enterprise Solutions

NGIC

NHA

Nikia Media

NILCO

NMP Insurance Services, LLC / NameMyPremium

Noridian Mutual Insurance Company

North American

Northern Capital

Northern States

Northland

North Pacific

North Pointe

Northpointe Bank

North Shore

Northwestern

Northwestern Mutual

Northwestern Mutual Life

Northwestern Pacific Indemnity

Northwest Pacific

Norvax

Norvax, LLC.

NRG

NuHealth

Number One Advertising

Number One Health

Number One Health Insurance Agency

Number One Prospecting

NuStar Insurance

Nxtlevel Health

NxtLevelHealth

Oak Hill Insurance

Oak Street Health

OctaneFire

Offer Advisors

Offer Strategy

Offerweb

OfferWeb.com

Official-Auto-Insurance.com

OHealth Group

Ohio Casualty

Ohio National Life

Ohio Security

Old Mutual US Life

Olympia

Omaha

Omega Auto Care

Omni Indemnity

Omni Insurance

Omnis Pro Insurance

ONCOR Insurance Services

One Health

OneMain Financial Group, LLC

One Touch Direct

Online Insurance Solutions

Online Insurance Solutions LLC

Onviant

Onviant Insurance Agency Inc.

Onyx Digital Media

OpenJar

Open Market Quotes

Opportunity Financial, LLC

Optimize.Ad

Optimum HealthCare

Oregon Mutual

Orion Ins.

Orion Insurance

Oscar

OSCAR Health

Oscar Health Insurance

Outlook Advisors

Overflow Works

Oxford

Oxford Health Plans

Oxford Insurance

Oxford Marketing Partners

Oxford Marketing Partners, LLC

Pacificare

Pacific Benefits Group

Pacific Benefits Group Northwest

Pacific Indemnity

Pacific Insurance

Pacific Life

Pacific Life and Annuity

Pafco

Pafco General Insurance

Palisades Media Group

Palmer Administrative Services

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 37 of 41

Palmetto Senior Solutions

Palms Health Group

Paloverde

Parachute Insurance Services Corp

Parasol Agents Network

Parasol Leads

Parasol Leads, Inc.

Path IQ

Patriot General

Patriot General Insurance

Pay Per Call Market

Peace of Mind Solutions

Peak Advertising

Peak Property and Casualty Insurance

Peak Protection Group

PEMCO

PEMCO Insurance

Penn America

Penn Mutual

Pennsylvania Natl

PennyMac Loan Services, LLC

PFP

Phoenix

Phoenix Life

Physicians Health Plan

Physicians Life

Physicians Mutual

Physicians United Plan

Pickett Group/TermLifeMatch

PickMedicare

Pier21 Media

Pietro Ancona

Ping Leads

Pinnacle

Pinney Insurance Center, Inc.

Pioneer Life

Pivot

Pivotal Concepts

Pivot Health

PJP Agency

PJP Health

PJP Health Agency

Plasmid Direct

Plasmid Media, LLC

Platform Advertising

Platinum Health Advisors

Platinum Health One

Platinum Health Solutions

Platinum Leads

Plymouth Rock

PMIC

PolicyBind, LLC

PolicyFuel

Policy Fuel LLC

Policy Impact LLC

Policy Ninja

Policy Post

PolicyScout

Policy Scout

Ponto Insurance

Powderhorn Media

Precise

Precise Health Insurance Advisors

Precise Leads

Precise Solutions Group

Precision Health

Precision Health Associates

Precursor Media

Preferred Abstainers

Preferred Care

Preferred Health Advisors

Preferred Mutual

Premera Blue Cross

Premier

Premier Business Solutions

Premier Disability

Premier Financial Alliance

Premier Health Association

Premier Health Choice

Premier Health Solutions

Premier Insurance Benefits, LLC

Premium Marketing

Premium Precision Marketing

Presbyterian Healthcare Services

Presbyterian Health Plan

Presidio

Presidio Interactive

Presidio Interactive Corporation

Prestige

Primary Health Care

Primary Insurance Group

Prime Care

Prime Care Health

Prime Healthcare Benefits

Prime Marketcare One

Primerica

Principal

Principal Financial

Principal Life

Priority Health

Priority Insurance

Priority One Health

Pristine

Pristine Media Group

Prodigy Health Agency

Prodigy Health Group

Professional Consultant Insurance Solutions

Progressive

Progressive Auto Pro

Progressive Insurance

Progressive Motorcycle

Prokey Wiseley Hamill

Propath Media

Prospect America Media, LLC

Prosperity Health

Prosurity

Protech Vehicle Services LLC

Protecta America

Protect America

Protective Casualty

Protective Life

ProtectMyCar

Protect My Car

Protect Your Home

Providence

Providence Health Plan

Providence Media Group

Provident

Prudential

Prudential Insurance Co.

Prudential of America

PURE

Puritan Health

Purple Dog Marketing LLC

Pyramid Life

Q3MInsuranceSolutions

Q3M Insurance Solutions, LLC

Qatalyst

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 38 of 41

QHS

Qualilty Healthcare Solutions

Quality

Quality Health

Quality Healthcare Solutions

Quality Healthcare Solutions, Inc.

Quality Insurance Solutions

Quantum3media

Quantum 3 Media

Quantum Research

QuickHealthInsurance.com

QuickInsured

Quick Life Center, LLC

Quick Quote

Quinstreet

QuinStreet

Quote.com

Quote Engine

Quotehound

Quotelab

QuoteLab, LLC

QuoteManage LLC

Quote Manager LLC

QuoteManager LLC

Quote Selection

Quote Selection Insurance Services, Inc

Quotestorm

Quote Velocity

QuoteWhiz

QuoteWhiz, LLC

QuoteWizard

Quote Wizard

Quotivia

Radwan Financial

Ralph Perez Insurance

Ramsey

Ranger

Rank Media

Rank Media Agency

RateForce

RBC Liberty Insurance

RCPT2

Real-Comp Data and Marketing

Reali Loans, Inc.

Real Results

Red Auto Protection

RedVentures

Redwing Consulting Services LLC

Reel Media Ventures

Regal

Regence

Reliance

Reliance First Capital, LLC

Reliance Insurance

Reliance National Indemnity

Reliance National Insurance

Reliant

ReliaQuote

Renaissance Health Services Corp.

Renew.com

Renew.com Inc.

Republic Indemnity

Reserve Compass LLC

Resource Connect

Response Insurance

Retirement Solution Leaders

Revi Media

Rev Impact

RevPoint

RevPoint Media

Rex Direct

RGAX

Right Advisors LLC

Ring Latino

Ring Router

Rocket Health Insurance

Rocket Health, LLC

Rocket Mortgage

Rockford Mutual

Rocking Ham Group

Rodney D. Young

Root

Royal United

RP Marketing

RSA

SafeAuto

Safe Auto

Safeco

Safeguard

Safeway

Safeway Insurance

Safeway Insurance Co of AL

Safeway Insurance Co of GA

Safeway Insurance Co of LA

Sagicor

Sales Data Pro

SalesHammer

SalesRadix

SaveToday

Savings Bank Life Insurance Company of

Massachusetts (SBLI)

Savings Bank Life Insurance Company of

Massachusetts (SBLI) Scan Health Plan

S.B. Fintech Ltd

Scan Health Plan

SCMS

Scott and White

Sea West Insurance

Secura

Secure Car Care

Secured Health

Secure Horizons

Security Health Plan of Wisconsin Inc.

Security Insurance

Security Insurance Co of Hartford

Security National

Security National Insurance Co of FL

Sedgwick James

SelectHealth

Selective Healthcare

SelectMyPolicy.com

SelectQuote

Select Quote

SelectQuote A&H;

SelectQuote Auto & Home

SelectQuote Insurance Services

SelectQuote Life

Select Quote Senior

SelectQuote Senior

Self Financial

SeniorCare Benefits

Senior Coverage

Senior Direct Insurance

Senior Healthcare Advisors

Senior Healthcare Direct

Senior Health Connect

Senior Health Connect Insurance Agency

Senior Health Direct

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 39 of 41

Senior Life

Senior Life Insurance Company

Senior Life Services

Senior Market

Senior Market Advisors

Senior Market Partners

Senior Market Quotes

Senior Market Sales

SeniorQuote Insurance Services

Sentara Health Management

Sentinel Insurance

Sentry

Sentry Group

Sentry Insurance a Mutual Company

Sentry Insurance Company

Sentry Insurance Group

Serenity

Shelter Insurance

Shelter Insurance Co.

Shelter Insurance Company

Shop RX Plans

Shore Life and Retirement Agency

Sicuro Health LLC

Sierra Health Services

Silent Affiliates

Simple Health

Simple Health Plans

Simple Insurance

Skandia TIG Tita

Smart Care Direct

Smart Final Expense

Smart Health Options, LLC

Smart Match Insurance Agency

Smart Match Insurance Solutions

Smart Relief Rx

SmartScripts & Affiliates

SmartScripts Agents

Smedley Insurance Group

Solar City

Solar Research Group

Solar Savings America

SolidQuote

SolidQuote LLC

SolidQuote, LLC

Spectrum Direct

Spectrum Health

Spring EQ LLC

Spring Health Plans

Spring Insurance

Spring Insurance Solutions

Spring Venture

Spring Venture Group

Stancorp Financial

Standard Guaranty

State and County Mutual Fire Insurance

State Auto

State Farm

State Farm County

State Farm Fire and Cas

State Farm General

State Farm Indemnity

State Farm Insurance Co.

State Farm Lloyds Tx

State Farm Mutual Auto

State Fund

State Mutual

State National

State National Insurance

Sterling

Sterling Senior Health

Stevens Insurance Agency

Stone Hill National

'Stone Tapert

StoneTapert Employee Benefits

Stone Tapert Insurance Services

StoneTapert Insurance Services Inc

St. Paul Companies

Strategy Bay

Stratum Media DMCC

Stringbit

STRINGBIT inc.

Success Mortgage Partners, Inc.

Suited Connector

SummaCare

Summit direct mail

Summit Health

Sun Coast

Sun Edison

Sun Life Assurance Company

Sun Power

SunPro Solar

Sunrise Health

Sunrun

Superior American Insurance

Superior Global Marketing Inc.

Superior Guaranty Insurance

Superior Home

Superior Insurance

Support First

Supreme Health Options, Inc.

Sureco

Sureco Legacy Insurance Services, Inc

Sure Health Plans

SureHits

Suretouch Leads

Sutter

SVG

Swiss Re

Symmetry Financial Group

Synergy Insurance

Synergy Insurance Marketing

Synergy Marketing Associates Inc

Tapert Insurance Agency Inc

Taylor & Associates

Taylored Legacy

Tech Insurance

Tech Leads

Teran Marketing

TGC Health, LLC

The Commerce Insurance Company

The Complete Lead

The Credo Group

The General

The Hartford

The Hartford AARP

The Healthcare Assistant

Thehealthcareassistant.com

The HealthScout

The Insurance Center

The Lead Company

The Lead Giant

The McGrp International

Themedicareassistant.com

The Rindal Agency

The Senior Resource Group

The-Solar-Project.com

The Zebra

This or ThatMedia

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 40 of 41

This or That Media

This or That Media Inc.

Three Rivers Holdings

Thrivent Financial for Lutherans

TIAA-CREF

Tiburon Insurance

Tiburon Insurance Services

TICO Insurance

TIG Countrywide Insurance

Tiger Health Solutions

Titan

Titan Indemnity

TK Insurance Services Inc

Tobias and Associates

Tobias & Associates

Together Health

Toggle

Top Flite

Top Healthcare Options

Torchlight

Torchlight Technology

Torchmark

Torr

Total

Total Advocacy Group LLC

Total Insurance Brokers

Touchstone

Tower

Towers Watson dba OneExchange

TPG Direct

Trademarc

Trademarc Global LLC

TradeMarc Global, LLC

Traders Insurance

Traffic Tree LLC

Transamerica

Trans America

Tranzact

Tranzact Insurance Solutions

Travelers

Travelers Indemnity

Travelers Insurance

Travelers Insurance Company

Trinity Universal

Triple-S Inc.

TriState

Tri-State Consumer

Tri-State Consumer Insurance

TruBridge

TruBridge, Inc

TruBridge, Inc.

True Auto

TrueChoice Insurance Services

Truecoverage

True Coverage

Trusource

TruSource

Tru Source

TruSource Marketing

TruStage

TrustedConsumer

Trusted Consumer Advisors

TrustedConsumer LLC

Trust Hall

Tryton

TSC Insurance

Tufts

Tufts Associates HMO Inc.

Tufts Health Plan

Twentieth Century

TWG

Twin City Fire Insurance

TZ Insurance Solutions

TZ Insurance Solutions LLC

Ucare

UMA

Underground Elephant

UniCare

Uniguard

Union

Unique Q2B

United Advisors LLC

United American/Farm and Ranch

United American Insurance Company

United Enrollment

United Financial

United Fire & Casual

United Health

UnitedHealthcare

United Healthcare

United Healthcare Advisors

UnitedHealthcare/UnitedHealthOne

UnitedHealthOne

United Insurance

United Insurance Group Agency, Inc.

United Medicare

United Medicare Advisors

United of Omaha

United Pacific Insurance

United Repair Programs

United Security

United Services Automobile Association

United States Fideli

Unitrin

Unitrin Direct

Unitrin Inc.

Universal American

Universal American Financial Corp.

Universal Health Advisors

Universal Health Care

UniversalHealthcareAdvisors

Universal Healthcare Advisors

Universal Underwriters Insurance

University Health Care Inc.

Unsure

UnumProvident Corp.

Upfront

UPMC

UPMC Health System

USAA

USA Benefits/Continental General

USA Dental Club

US Benefit Solutions

USDS (US Dealer Services)

USF and G

USF&G;

U S Financial

US Financial

US Financial Life

US Health Advisors

USHealth Advisors

US Health Group

USHEALTH Group

USInsuranceOnline

US Saving Center

US Web Leads

Utah Home and Fire

Utica

Reply Comments of 28 State AGs, CG Docket Nos. 21-402 & 02-278 Page 41 of 41

Valley Peak Insurance Group

Vanguard Health Ventures

Vantis Life

Vasa North Atlantic

Vehicle Assurance Co

Velapoint

VelaPoint Personal Insurance

Verengo

Verified Insurance Lead

Versible Connect

Versus Media Group

Verti Insurance

Verti Insurance Company

Veterans United Home Loans

Vigilant

Viking

Viking County Mutual Insurance

Viking Insurance Co of WI

VIMO

Visiqua

Visiqua LLC

Vitalone

Vitalone Health

Vital One Health

VitalOne Health Plans

Vital One Health Plans Direct, LLC

Viva Health

VSC Digital

VSC Group

Walking Tree Creative LLC

Warranty Agents

Warranty Direct

Wasatch Marketing Group

Washington National Life

Washington United LLC

Wawaunesa

Wax Digital Solutions

WEA Inc.

WebTec

we-Call Media

Wejo

Wellcare

WellCare Health Plans

Wellington

Wellness Plan of America

WellPoint

We Speak

West American

West Bend Mutual

Westcoast Closers

West Coast Closers

Western and Southern Life

Western Mutual

Western National

Western & Southern Financial

Western & Southern Life

Westfield

West Field

West Plains

Wholesale

Whoop Media

William Penn

Windhaven

Windsor

Windsor Insurance

Windstar

Wisconsin Mutual

Woodlands Financial Group

World Insurance

World Mail Direct USA

World of Insurance

Worldwide

Wyndham Capital Mortgage, Inc

WynnHealth

XLHealth

XLHealth.

Yellow Key

Yosemite

Young Life & Wealth

YourHealthCareQuotes.com

Your Help HQ

Your Lowest Quote

Zander

Zebra

ZebraA1333

Zenith Media

Zillow Home Loans, LLC

Zoom Insurance

ZQ Auto Insurance

ZQ Sales

Zurich

Zurich North America

Zurich North America or other partners