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Well, as ever, there's lots of black and white answers to a grey issue here. For example, it's entirely within the bounds of acceptability according to the FTC (well, strictly speaking, some lawyers who predict what the FTC's view on something might be) to promote a dialler as being FREE* if, for example, the first two minutes of the call are free. You'll probably have seen this sort of promotion on psychic services and so on. Problem is that this sort of thing will lead to even higher chargebacks than usual..
Dave
*first two minutes, then billed at $3.99/minute.
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