Recent Class Certification Against Bank Shows Risks of Wrong Numbers and Reassigned Numbers

A recent class certification ruling by the District Court in Arizona demonstrates several of the most dangerous aspects of the Telephone Consumer Protection Act (TCPA). The case—Head v. Citibank—stems from alleged violations committed by a bank while making collections calls. The class contains over a million people, many of whom may have received more than… Continue reading Recent Class Certification Against Bank Shows Risks of Wrong Numbers and Reassigned Numbers

FCC Proposes Declaratory Ruling Stating That Ringless Voicemails Are Robocalls

Federal Communications Commission (FCC) Chairwoman Jessica Rosenworcel announced a new proposed Declaratory Ruling and Order that would affirm that ringless voicemail (RVM) technology is subject to the same Telephone Consumer Protection Act (TCPA) consent requirements as prerecorded calls. If enacted, it would find that “ringless voicemails are, in fact, ‘calls’ that require consumers’ prior express consent.” The… Continue reading FCC Proposes Declaratory Ruling Stating That Ringless Voicemails Are Robocalls

The TCPA and Personal Liability

Litigation under the Telephone Consumer Protection Act (TCPA) generally targets companies, whether that means telemarketing companies or the sellers that hire them. But there is a legal precedent for TCPA complaints—and the potentially expensive penalties that go with them—to be filed against employees and corporate officers under a theory of individual liability.

30 Years of the TCPA

Today is the 30 year anniversary of President George H.W. Bush signing the Telephone Consumer Protection Act (TCPA) into law. It is fitting that this anniversary is somewhat overlooked as, for the first two decades of its existence, the TCPA served its intended, modest purpose as a statute allowing individual consumers to bring lawsuits in… Continue reading 30 Years of the TCPA

Wrong Numbers Are a TCPA Risk

Wrong numbers sometimes take a backseat to reassigned numbers when discussing Telephone Consumer Protection Act (TCPA) risks. But they represent a similar sort of risk without counterbalancing features like the Reassigned Numbers Database (RND) and its associated safe harbor. Understanding why wrong numbers serve as a source of TCPA risk and implementing measures to mitigate that risk are essential parts of TCPA compliance.

Just the Fax, Ma’am

30 years after the passage of the TCPA, fax machines might not be used as often as they once were but faxes remain a source of TCPA litigation.  Here are some notable TCPA fax cases from this year.