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I didn't say every time they make a call. But everyone who is able to make a call. I don't see any reason a user of a payphone is not a customer of the payphone provider for example.

We'll have to wait for the final guidance from the FCC, but as a telecoms provider I'm quite concerned about the direction.

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May I submit you do see the reason, even, you named it? :) They are a user of a payphone, not subleasing a number that could be used for robodialing.
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And if they stand at the payphone and make scam calls for an hour and someone reports this and the payphone operator gets asked to identify this customer of theirs?
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Then a police officer can visit the payphone and find out.
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