Class Action and Product Insights for Your Business
March 20, 2018 - TCPA, Class Action

An Autodialer Ain’t What It Used to Be: D.C. Circuit Rejects FCC’s Broad Ruling on the TCPA’s Scope

Federally-Backed Debt Collection Exception Not the Supreme Court’s Cup of T(CPA)

Late last week, the D.C. Court of Appeals issued its much-anticipated ruling in ACA International et al. v. Federal Communications Commission, No. 15-1211 (Mar. 16, 2018).The ruling appears to pare back significantly the scope of activity that may be subject to the Telephone Consumer Protection Act, 47 U.S.C. 227, and its implementing regulations at 47 C.F.R. 64.1200 (collectively, the “TCPA”), as interpreted by the Federal Communications Commission (“FCC”).