On June 17, a number of organizations filed comments in response to TracFone’s Petition for Rulemaking, in which it requested that the FCC ban all in-person distribution of Lifeline handsets.  TracFone asserted that such a ban would cut down on fraudulent enrollments, which it alleges occur more often in live settings, particularly when ETCs distribute handsets in tents and on street corners.  Numerous ETCs, state governments, and advocacy groups filed comments on this proposal with the FCC, with the vast majority opposing it.  Several ETCs claimed that TracFone’s proposal was arbitrary, since it provided no data to back up its claim that in-person distribution is more prone to abuse than alternative channels, which include enrollment by phone, mail, and the Internet.  Others questioned the FCC’s authority to adopt such a proposal or whether such a proposal is consistent with the First Amendment.