Michael Geist, professor of law at the University of Ottawa, has criticized the changes adopted in the amended Act. He observed that the legislation contained too many exemptions which would not result in a significant decrease in calls for subscribers of the DNCL. Geist expressed particular concern about the extent and duration of the existing business relationship exception. In a 2009 article for the "Toronto Star," Geist labelled the CRTC's do-not-call list a "disaster" and recommended that parliament return to the original version of Bill C-37 by eliminating all exemptions. He further recommended cross-border cooperation to resolve jurisdictional issues and immediate tough enforcement to send a strong signal to violators.