You’ll need debounce which might as well be done is software. The probably eliminates using COUNT unless you do hardware debounce.
I never got a very reliable DTMF out of PBP, even with 20MHz crystal.
If you can go higher, you might get something decent out of DTMFOUT or FREQOUT.
I set the entire phone number to be dialled into an array, and output all of the DTMF at once after a period of inactivity of the dial.
There is also a HOME switch in the dial that is open whenever the dial isn’t in the home position that allows you to end your count
with confirmation that no more pulses are coming, and to look to start counting the next digit dialled.




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