> The FCC has effectively said "here's a list of words that are considered reasonable opt out words and let the courts decide what is reasonable when there is a dispute." They're basically deferring to the courts to determine reasonableness.

Yikes. The lawyer dog comes to mind (a Fifth and Sixth Amendment Supreme Court case). Suspect speaks voluntarily to police until he realizes they suspect him of a crime. He stops and says, "I want a lawyer, dawg." What is meant to happen then is that the interrogation is stopped until that point. Police carried on the interrogation, and the Court ruled that statements he made in that period of time were admissible in securing a conviction against him.

When this was appealed, the Louisiana Supreme Court declined to hear it, saying, with a completely straight face, that there was ambiguity, and that since the police could reasonably believe that he was in fact asking for a canine lawyer, i.e. Lawyer McDog, Esquire, and that they couldn't find such an attorney, there was no invocation of counsel that warranted a termination of the interview.